The FCA proposes moving away from the PRIIPs KID to a more flexible, technologically neutral regime, which allows firms to innovate and prioritise good customer outcomes.
By Rob Moulton, Nicola Higgs, Becky Critchley, Sidhartha Lal, and Charlotte Collins
On 19 December 2024, the FCA published a consultation on its proposed rules for the new Consumer Composite Investments (CCI) regime (CP24/30). As part of the Edinburgh Reforms, the UK government committed to repealing the Packaged
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.
“Fair access” banking laws, at the epicenter of the debates between ESG and “anti-woke” regulation and federal/state preemption, may see a resurgence under the incoming administration.
By Betty M. Huber, Arthur S. Long, Pia Naib, Austin J. Pierce, and Deric Behar
In recent years, the landscape of “fair access” banking laws, now also known as “anti-debanking” laws, has changed as quickly as the shifting political climate.
Federal and state fair access laws and regulations are legislative
The consultation covers new methodologies for the financial sector’s GHG emissions reporting, including regarding avoided emissions, or “scope 4” emissions.
By Paul A. Davies, Nicola Higgs, Michael D. Green, Jaime Martin, James Bee, and Charlotte Collins
On 3 December 2024, the Partnership for Carbon Accounting Financials (PCAF) launched a consultation to gather financial industry feedback on its newly proposed methodologies for measuring and reporting greenhouse gas (GHG) emissions associated with financial activities.
As part of
By Arthur Long and Pia Naib
In 2024, the US federal bank regulators were extremely active, with initiatives ranging from antitrust and capital to proposals regarding controlling shareholders and incentive-based compensation. Climate issues and resolution planning were also areas of focus.
With the election of Donald J. Trump to a second term as president of the US, however, the next four years will be a time of deregulation.
Read this article that discusses the regulators’ initiatives and their likely future
As AI use proliferates, the advisory reminds CFTC-regulated entities of their existing obligations and the CFTC’s intention to monitor for ongoing risks.
By Douglas K. Yatter, Yvette D. Valdez, Margaret Graham, Hanyu (Iris) Xie, Adam Bruce Fovent, Mia Stefanou, and Deric Behar
On December 5, 2024, the staff of the Commodity Futures Trading Commission’s (CFTC) Divisions of Clearing and Risk, Data, Market Oversight, and Market Participants published an advisory on the use of artificial
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 latest guidance from the FCA focuses on Consumer Duty board reports and how firms handle complaints and root cause analysis.
By Becky Critchley and Charlotte Collins
On 11 December 2024, the FCA published two pieces of feedback on the Consumer Duty, setting out good practices and areas for improvement in relation to Consumer Duty board reports and complaints and root cause analysis. These publications have been compiled to share the FCA’s insights on how different firms have started to embed the Consumer Duty across the financial services industry. The FCA aims to assist firms in meeting their Consumer Duty obligations by conducting a range of post-implementation work, as outlined in its Consumer Duty workplan.
Firms will find it particularly helpful to receive guidance on the FCA’s expectations regarding board reports. Previously, firms did not receive a prescribed template and found compiling their first reports challenging, both in terms of form and content. Firms will be keen to understand how they can improve their next board reports and meet FCA expectations.
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
With appropriate safeguards, distributed ledger technology may expand the use of non-cash assets as derivatives collateral, while mitigating certain market infrastructure inefficiencies.
By Yvette D. Valdez, Adam Bruce Fovent, and Deric Behar
On November 21, 2024, the Digital Asset Markets Subcommittee (the Subcommittee) of the Commodity Futures Trading Commission’s (CFTC) Global Markets Advisory Committee (GMAC) issued a report (the Report) that recommended expanding the use of non-cash collateral in derivatives markets through distributed ledger technology (DLT).
In the