UK FCA No Deal Brexit Preparations
On Oct. 7, UK FCA issued market watch issue 61 on no-deal Brexit.
- Followed Mar. 2019, FCA supervisory statement on regime post-Brexit, see #52800.
- Follows UK FCA Aug. 2019 market watch 60 on inside information, AML, see #63603.
- No-Deal Brexit
- Important information to help firms prepare for a possible no deal Brexit on Oct. 31.
- FCA website is being updated and in Sep. 2019 CEO spoke on no deal, see #64997.
- He highlighted outstanding issues which require further action from the UK or the EU.
- Including prospect of overlapping EU and UK share trading obligations for MiFID firms.
- Emphasized firms should consider these issues as part of their contingency planning.
- MiFID Transaction Reporting
- Temporary transitional power is intended to minimize disruption if there is no-deal.
- Follows FCA Jul. 2019 extension of the temporary transitional power, see #63101.
- But this is not appropriate regarding the transaction reporting rules under MiFID II.
- Such reports are crucial for FCA market oversight and integrity of financial markets.
- Firms and connected persons, e.g. approved reporting mechanisms, should take reasonable steps to comply with changes to their regulatory obligations by exit day.
- Following UK FCA Sep. 2019 issued draft directions under Brexit TTP, see #65489.
- Firms unable to comply fully with regime at time of a no-deal withdrawal must be able to back-report missing, incomplete, inaccurate transaction reports as soon as possible.
- MiFID Transparency Regime
- Update on how MiFID transparency regime will work in the event of no deal, covering FITRS, DVC, equity, non-equity transparency, systematic internalizers, tick sizes.
- Takes account of ESMA statement issued Oct. 7, 2019, giving details on operation of ESMA databases and performance of MiFID II calculations in case of no-deal.
- Industry Testing- FCA FITRS
- As part of the development of the post-exit MiFID regime, industry testing for FCA FITRS (Financial Instruments Transparency System) will open on Oct. 10, 2019.
- Oct. 2019 EU ESMA Update
- On Oct. 7, 2019, ESMA issued updated measures on no-deal Brexit, see #65961.
||B/D; Bank; BS; CNSM; Corp; Exch; Fiduciary; HF; IA; Ins; Inv Co; MSB; OTC
||MW 61, PR, 10/7/2019; EUWA; MIFID/MIFIR Dir 2014/65, Reg 600/2014; Brexit
||BCS; Compliance; Financial; Legal; Operations; Privacy; Risk; Trade Reporting; Trading; Treasury
||European Union; United Kingdom; Cross-Border
||Banking; Clearing; Corporate; CRA; Derivatives; Fund Mgt; Hedge Funds; Insurance; Mutual Funds; Securities; Structured Products
|Reg. Last Update
Last substantive update on 10/08/2019