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Road to COP29: Our insights
The 28th Conference of the Parties on Climate Change (COP28) took place on November 30 - December 12 in Dubai.
Quarterly UK financial services horizon scanner
United Kingdom | Publication | April 2024
Introduction
In this briefing we set out some of the key upcoming dates that we are aware of so far in the financial services space for 2024, together with links to our relevant content for each development. We will publish an updated version of this horizon scanner next quarter.
For further detail on some of these developments, please also see our briefing, Horizon scanning: Ten regulatory topics to look out for in 2024. In addition, for a regular weekly look-ahead to upcoming regulatory developments in the financial services space, please see our Regulation Tomorrow blog.
Content
Expected key dates for H1 and H2 2024
| H1 2024 | Policy paper and proposals for further reform on aligning ringfencing and resolution regimes are expected – see our blog |
| FCA aiming to make draft rules following recommendations of the Investment Research Review (it previously noted that it was targeting consultation for Q1 2024). | |
| Consultation responses and policy statements due from PRA and FCA on respective securitisation rules (by Q2 2024). | |
| New FCA rules to incorporate aspects of the Tailored Support Guidance (TSG) expected to come into force, and TSG expected to be withdrawn. | |
| PRA expected (in Q2) to publish near-final policies on remaining elements from CP16/22: credit risk, the output floor, and reporting and disclosure requirements. | |
| FCA and PRA consultation on SM&CR expected (April – June 2024) – as confirmed in the latest Regulatory Initiatives Grid | |
| FCA expected to publish a consultation paper on UK PRIIPs Regulation and UCITS disclosure requirements – as confirmed in the latest Regulatory Initiatives Grid. | |
| H2 2024 | FCA aiming to consult on rules to implement reformed prospectus regime (in summer 2024) – as confirmed in the latest Regulatory Initiatives Grid. |
| FCA and PRA policy statements expected to follow up on consultation papers on diversity and inclusion in financial services. | |
| Policy statement expected following CP23/24 on personal investment firms. | |
| More detailed proposals expected to be published by HM Treasury (for consultation) on the reform of the Consumer Credit Act 1974 – as confirmed in the latest Regulatory Initiatives Grid. | |
| Policy statement expected on the alignment between ring-fencing and resolution – as confirmed in the latest Regulatory Initiatives Grid | |
| FCA and PRA expected to consult on further changes to securitisation rules (Q4 2024/Q1 2025) – as confirmed in the latest Regulatory Initiatives Grid |
Expected and known key dates for the coming months
April
| During April 2024 | Payment Systems Regulator expected to consult on a direction requiring in-scope PSPs to report data to Pay.UK for Faster Payment System monitoring purposes. |
| 5 April 2024 | The rules set out in the Policy Statement for the framework for UK consolidated tape, published as part of FCA CP23/33, come into force. The FCA aims to finalise its associated rules by that date. |
| 8 April 2024 | Deadline for responses to:
|
| 16 April 2024 | Deadline for responses to FCA CP24/2 on the FCA’s Enforcement Guide and new approach to publicising enforcement investigations. |
| 17 April 2024 | Deadline for responses to HMT consultation on the Private Intermittent Securities and Capital Exchange System (PISCES). |
| 26 April 2024 | Deadline for expressions of interest in advancing emerging use cases for fund tokenisation to be made to the Technology Working Group. |
| 30 April 2024 | Deadline for responses to:
|
| 30 April 2024 | Deadline for responses to BoE discussion papers on Real Time Gross Settlement (RTGS) service operating hours and access policies. |
| 30 April 2024 | Key regulators including the FCA and BoE have been asked to publish an update by this date outlining their strategic approach to artificial intelligence (AI). |
May
| 31 May 2024 | Anti-greenwashing rule and related guidance comes into force for all FCA regulated firms. See our blog and briefing. |
June
| During June 2024 | PRA expected to publish final statement of policy on its proposed approach to rule permissions and waivers, following CP3/24 |
| 9 June 2024 | Deadline for responses to HMT consultation on improving the effectiveness of the Money Laundering Regulations. |
| By end June 2024 | FCA expected to report on its review of the treatment of domestic politically exposed persons by financial services firms – see our blog. |
| Summer 2024 | Expected implementation date for PRA supervisory statement and FCA guidance on prudential assessment of acquisition and increases in control, following PRA CP25/23 and CP23/23. |
July
| 1 July 2024 | Remaining rules under PRA’s Strong and Simple Framework take effect. |
| 31 July 2024 | Firms can begin to use investment labels with accompanying disclosures under the FCA’s sustainability disclosure requirements – see our blog and briefing |
| 31 July 2024 | Deadline for application of Consumer Duty to closed products and services – see our recent blogs here and here. |
August
| No key dates to highlight for this month so far. |
September
| 30 September 2024 | New FCA and BoE rules on reporting requirements under UK EMIR come into force. |
| End September 2024 | LIBOR transition – the synthetic 1, 3 and 6 month US dollar LIBOR are intended to cease – as confirmed in the latest Regulatory Initiatives Grid and see also our blog. |
October
| October 2024 | The final group of payment services providers will need to implement a system to provide the Confirmation of Payee service – as confirmed in the latest Regulatory Initiatives Grid. |
| 1 October 2024 | The PRA’s new Recovery Plans Chapter 7 comes into force. Firms are also expected to meet the expectations in SS2/24 by the same date. For more information, see our blog. |
| 7 October 2024 | The PSR’s rules on mandatory reimbursement for APP fraud takes effect and the Payment Services (Amendment) Regulations 2024 come into force. |
November
| 25 November 2024 | Changes to the UK SFTR Validation Rules and XML schemas start to apply. |
December
| 2 December 2024 | Naming and marketing rules under the FCA’s SDRs start to apply – see our blog and briefing. |
Recent publications
Publication
Country risk in unprecedented times: A precedent for cross-border loan documentation?
While country risk cannot be avoided in cross-border transactions entirely, it can be effectively mitigated through careful transaction structuring and tailored contractual protections.
Publication
The GCR Guide to Life Sciences – Merger control: Procedural issues
Miranda Cole, Julien Haverals and Emma Clarke of our Brussels/ London offices are the authors of a chapter on procedural issues in merger control that has been published in the third edition of the Global Competition Review’s The Guide to Life Sciences. This covers a number of significant procedural developments that have affected merger review of life sciences transactions.
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