A Republican Congress and the incoming Trump administration may employ the CRA to quickly overturn recent rules that faced heavy criticism from the financial services industry.
By Jenny Cieplak, Zachary Fallon, Arthur Long, Parag Patel, Barrie VanBrackle, Stephen Wink, and Deric Behar
Every four years in American politics is an opportunity to turn the tables on the party in power. But leading up to and following an election that shifts control of the government
In this publication and podcast series, we explore some of the core focus areas for UK-regulated financial services firms in the year ahead.
In 2024, we saw disruption to the regulatory reform agenda as the unexpected timing of the general election impacted work and publication schedules. Now that the reform agenda is back on track and aligned to the new government’s plans for growth, we are likely to see improved progress on existing reforms as well as fresh initiatives in the pursuit of growth during 2025.
There is doubtless a strong focus on retail markets under the new government, but the UK’s competitiveness as a place to do business remains vital as improvements to the UK’s wholesale markets continue. ESG and AI continue to dominate across the sector as rapidly evolving areas that profoundly impact the regulatory landscape.
The proposals aim to drive more consistency in operational incident reporting and greater visibility in the use of material third-party services.
By Rob Moulton and Charlotte Collins
On 13 December 2024, the FCA and the PRA published linked Consultation Papers on operational incident and third-party reporting (FCA CP24/28 and PRA CP17/24). The consultations aim to create a structured framework for financial services firms to report operational incidents and material third-party relationships. The proposals will help standardise the information that the regulators receive and enable them to identify systemic problems related to incident and third-party risk management.
The FCA is approaching its design of the world’s first regulated private/public crossover market with a “private plus” rather than a “public minus” mindset.
By Mark Austin, Rob Moulton, James Inness, Anna Ngo, Frederick Gardner, and Johannes Poon
On 17 December 2024, the FCA launched a consultation on its proposed regulatory framework for the Private Intermittent Securities and Capital Exchange System (PISCES) (CP24/29). This consultation follows the publication of HM Treasury’s draft statutory
When the Edinburgh Reforms were announced on 9 December 2022, they were billed as an ambitious set of reforms. Two years on, we assess which of the measures have been completed, which remain outstanding, and whether they have delivered on the agenda set out.
We also reflect on the recent Mansion House announcements, which have reset the future of regulatory reform.
The regulator has significantly rowed back on aspects of the proposals following industry and government feedback.
By Andrea Monks, Rob Moulton, Nell Perks, Anna James, and Charlotte Collins
On 28 November 2024, the FCA published revised proposals for announcing enforcement investigations. The original consultation, launched in February 2024, proved to be one of the most controversial proposals put forward by the regulator and received an unprecedented response from industry and the government (for more detail on the original proposals, see this Latham blog post). The FCA has attracted a great deal of criticism since the launch of the first consultation, culminating in an evidence session before the House of Lords Financial Regulation Committee a few weeks ago, which made for uncomfortable viewing.
In light of the feedback received, the FCA has made some significant changes to its proposals, and acknowledges that it ought to have handled their communication better by signalling the proposals to the market in advance of their publication. The regulator also acknowledges the importance of considerations around its secondary objective relating to international competitiveness and growth in relation to these proposals.
The new regime will take effect on 1 January 2025, but will not diminish the responsibilities of financial services firms relying on the services of critical third parties.
By Rob Moulton, Fiona Maclean, Alain Traill, and Charlotte Collins
On 12 November 2024, the PRA, FCA, and Bank of England jointly published a Policy Statement (PRA PS16/24 and FCA PS24/16), setting out their final rules for critical third parties (CTPs). The regulators consulted on this framework in December
The UK Chancellor announces a growth-focused agenda for financial services.
By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins
On 14 November 2024, the new Chancellor of the Exchequer, Rachel Reeves, delivered her first Mansion House speech. She used her speech as an opportunity to announce reforms designed to drive growth and competitiveness in financial services, stating that many of the regulatory changes introduced to eliminate risk after the financial crisis had “gone too far” and led to unintended consequences. Although she did not announce a swathe of deregulatory measures, this speech sets the tone for how the government will likely approach regulation in the financial services sector going forward.
The data provides important insights to assist firms with their ongoing work in this area.
By Rob Moulton, Nicola Higgs, Nell Perks, Becky Critchley, and Charlotte Collins
On 25 October 2024, the FCA published the results of a survey on non-financial misconduct it undertook earlier in the year involving over 1,000 firms in the wholesale sector (investment banks, brokers, and wholesale insurance firms). This was the first time the FCA has looked in detail at how
PRA and FCA speeches recap the regulators’ work to deliver growth and enhance competitiveness, and outline some key upcoming policy work.
By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins
On 17 October 2024, the PRA and the FCA both published speeches given by their Chief Executives at the Annual City Banquet. Although the speeches cover different topics on the regulators’ policymaking agendas, both focus on how the regulators will further their new secondary objective to