December 2020: The month ahead in financial services regulatory developments…

30 November 2020

In this blog post, we round-up forthcoming developments in the UK and at EU and International levels in financial services regulation which are expected for December 2020.

1 Dec	Deadline for responses to FCA call for input (CfI) on Woolard Review into unsecured credit market regulation
2 Dec	Consumer Credit (Enforcement, Default and Termination Notices) (Coronavirus) (Amendment) Regulations 2020 enter into force Deadline for responses to Department for Digital, Culture, Media and Sport (DCMS) consultation paper (CP) on a National Data Strategy
3 Dec	Deadline for insurance firms to review their product lines in response to FCA Final Statement 20/7 (FS20/7) on product value and Covid-19 Deadline for transposition of the Directive on combating money laundering by criminal law
4 Dec	Deadline for expressions of interest in accessing and/or comments regarding the Payment Systems Regulator's (PSR's) confidentiality ring in relation to card-acquiring services market review Deadline for responses to European Securities and Markets Authority (ESMA) CP on draft advice under Art 8 of Taxonomy Regulation
7 Dec	Senior Managers and Certification Regime (SMCR) extension to benchmark firms, following on from FCA of Policy Statement 20/5 (PS20/5) Deadline for responses to European Banking Authority (EBA) digital platforms industry survey 2020 Deadline for responses to International Association of Insurance Supervisors (IAIS) stock-take questionnaire on infrastructure and strategic equity
8 Dec	Deadline for responses to PSR interim report on the card acquiring market review [the PSR announced on 27 November, that it intended to extend the consultation period and will make an announcement in due course, please see also the 4 December 2020 PSR entry] Payment Services and Electronic Money (Amendment) Regulations 2020 come into force Deadline for responses to European Commission roadmap for ‘Banking Union: Review of the bank crisis management and deposit insurance framework’ (BRRD Review)
9 Dec	Fund managers to have emailed FCA to confirm update of previously submitted notifications under the Temporary Permissions Regime (TPR) (updated notifications to be submitted from 14 Dec)
10 Dec	Record of Financial Policy Committee (FPC) November 2020 policy meeting to be published Delegated Regulation on fees for securitisation repositories (SRs) comes into force
14 Dec	FCA to begin to publish details of directory persons at solo-regulated firms Deadline for responses to EBA CP on revision of guidelines on major incident reporting under revised Payment Services Directive (PSD2) Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2020 come into force
15 Dec	Deadline for responses to FCA CfI on consumer investments market Update to list of global systemically important institutions (G-SII) (annual)
16 Dec	PRA to apply Pillar 2A reduction (PS15/20) on or before this date
18 Dec	Deadline for responses to European Commission CP on Delegated Regulation on climate change mitigation and adaptation under Taxonomy Regulation Deadline for responses to two European Commission draft delegated regulations under the Pan-European Personal Pension Product (PEPP) (available here and here) Commission to submit report on amendments to the Markets in Financial Instruments Regulation (MiFIR) trading obligation following EMIR REFIT
21 Dec	EMIR: Interest rate and credit derivatives – end of extension of deferred date of application of clearing obligation and bilateral margin requirements for intragroup transactions with a third country group entity
24 Dec	Deadline for responses to the Department for Business, Energy and Industrial Strategy (BEIS) CP on increasing the powers of the Small Business Commissioner, including enforcement
26 Dec	EBA to submit various Investment Firms Regulation (IFR)/Investment Firms Directive (IFD) technical standards to European Commission (phase 1 roadmap)
27 Dec	Existing systemically important investment firms must apply for authorisation under Art 8 Capital Requirements Directive IV (CRD IV) by this date (Art 62(6) IFD) (except UK authorised firms)
28 Dec	FCA to publish final rules and guidance following CP20/14: Updating the Dual-regulated firms Remuneration Code to reflect CRD V by this date; PRA to publish rules following CP12/20 CRD V by this date CRD V transposition (measures to apply from 29 Dec 2020); Art 3(4) CRR II (incl measures relating to prudential consolidation) applies Transposition deadline for BRRD II Single Resolution Mechanism Regulation (SRMR II) applies
29 Dec	CRD V applies, remuneration changes proposed in PRA CP12/20 Final EBA guidelines on subsets of exposures in application of systemic risk buffer (SyRB) apply
30 Dec	TPR notifications to be submitted by firms Financial Services and Economic and Monetary Policy (Consequential Amendments) (EU Exit) Regulations 2020 come into force European Supervisory Authorities (ESAs) to develop draft RTS by this date under SFDR on: transparency relating to sustainability indicators on climate and environment-related adverse impacts presentation and content of pre-contractual disclosures and periodic reports website transparency requirements
31 Dec	Deadline for applications for cohort 7 of FCA regulatory sandbox FCA deadline for applications to participate in Global Financial Innovation Network (GFIN) cross-border testing of financial products and services Expected date for changes to PRA Supervisory Statement 11/16 (SS11/16) to come into effect following CP11/20 on Solvency II: the PRA’s expectations for the work of external auditors on the matching adjustment PS7/19: Application date of amended rules in Credit Risk Part of PRA Rulebook and updated SS11/13 (as set out in PS7/19) UK autonomous sanctions under Sanctions and Anti-Money Laundering Act (SAMLA) to be brought into force (subject to negotiation during the transition period) Provisional end date for UK Government guarantee of business-to-business transactions supported by Trade Credit Insurance EBA updated guidelines on harmonised definitions and templates for credit institutions’ funding plans enter into force EBA reporting framework 2.10 amendments incl the integration of remuneration benchmarking templates into DPM and XBRL taxonomies applicable from this date Deadline for responses to ECB CP on draft Eurosystem oversight framework for electronic payment instruments, schemes and arrangements Deadlines for responses to the International Financial Reporting Standards (IFRS) Foundation CP on sustainability reporting
Dec	Publication of FCA vulnerability guidance Bank of England (BoE) and FCA publish final EU Exit Instruments (binding technical standards and rules) and Temporary Transitional Power (TTP) Directions Suspicious Activity Reports (SARs) Transformation Programme due to deliver first tranche of SARs IT transformation and target operating system Results of EBA 7^th annual transparency exercise EBA Implementing Technical Standards (ITS) on investment firm disclosures EBA to finalise draft Regulatory Technical Standards (RTS) and Communication to European Commission on indirect subscription of Minimum Requirement for own funds and Eligible Liabilities (MREL) instruments within groups under BRRD 2 EBA to publish final report of findings from onsite reviews in 2019/20 of National Crime Agency (NCA) approaches to anti-money laundering (AML) supervision Financial Stability Board (FSB) annual resolution report, final guidance on financial resources to support central counterparty (CCP) resolution and stocktake of practices in implementation of total loss-absorbing capacity (TLAC) standard FSB annual global monitoring report on non-bank financial intermediation

Related categories

Bank Accounts and Payment Services Banking Climate Change Corporate Crime Credit and Loans Crisis Management Cross-border EU FinTech Insurance International Investment Management LIBOR Discontinuation Market Abuse / Insider Trading Markets Money Laundering Operational Resilience Outsourcing Prudential Regulatory Reporting Retail Investments and Pensions Sanctions Sustainable Finance UK

Key contacts

Karen Anderson

Consultant, London

Susannah Cogman

Partner, London

Elizabeth Head

Of Counsel, London

Hannah Cassidy

Partner, Head of Financial Services Regulatory, Asia, Hong Kong

Clive Cunningham

Partner, London

Marina Reason

Partner, London

Kelesi Blundell

Partner, London

Jenny Stainsby

Global Head – Financial Services Regulatory, London

Hywel Jenkins

Partner, London

Chris Ninan

Partner, London

Jon Ford

Partner, London

Valerie Tao

Professional Support Lawyer, Hong Kong

Cat Dankos

Regulatory Consultant, London

Patricia Horton

Professional Support Lawyer, London

Disclaimer

The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.

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December 2020: The month ahead in financial services regulatory developments…

Related categories

Key contacts

Karen Anderson

Susannah Cogman

Elizabeth Head

Hannah Cassidy

Clive Cunningham

Marina Reason

Kelesi Blundell

Jenny Stainsby

Hywel Jenkins

Chris Ninan

Jon Ford

Valerie Tao

Cat Dankos

Patricia Horton

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