RegZonewww.law-now.com/regzone

January 2012

Risk, Governance and ARROW

CMS Cameron McKenna

CMS Cameron McKenna is an international commercial law firm advising businesses, financial institutions, governments and public sector bodies. We are a founding member of CMS - the alliance of independent European law firms. CMS law firms provide clients with access to integrated pan-European legal services, managed by a single point of contact and with common high calibre service standards. The organisation has over 58 offices and associated offices worldwide. In Europe, CMS Cameron McKenna is a top-ten law firm in its own right with over 130 partners and c 700 legal and tax advisers (including partners). We have the resources and experience to advise clients on a wide range of transactions and projects both in the UK and internationally. We have offices and associated offices in various key business centres worldwide including the UK, Central Europe, Russia, Asia and North America. Our lawyers have strong specialist expertise in areas such as finance and financial services; competition and European law; corporate; consumer products; tax; utilities and natural resources; real estate, hotels and environment; insurance and reinsurance; cross-border investment; technology, lifesciences and intellectual property; infrastructure and projects; human resources and pensions; arbitration and litigation. We have a strong track record in the financial services sector across Europe and are therefore very familiar with the key issues affecting clients at the moment. We are committed to providing the highest quality professional advice and building enduring relationships with our clients. We place great emphasis on the training and development of our partners and staff in both current legal and business issues. Our investment in know-how and information systems allows us to share our knowledge and experience throughout the firm, helping to ensure that all our lawyers add value to the services they provide. We work with our clients to identify their business needs and provide them with comprehensive, cost-effective commercial guidance, we offer a clear business lead - not just legal opinion. CMS Cameron McKenna is a member of Scottish Financial Enterprise.

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Speakers

Simon Morris

Partner, Financial Services

T +44 (0) 20 7367 2702

E simon.morris@cms-cmck.com

Simon joined Cameron McKenna in 1980, qualified as a solicitor in 1982 and has been a partner since 1988. He

is a member of the firm’s financial services group and specialises in advising financial services institutions on

commercial and regulatory matters. Simon has acted on a number of acquisitions and product launches, and has

represented over 250 firms in regulatory and disciplinary proceedings. Simon is author of Financial Services:

Regulating Investment Business, and is a member of the City of London Law Society Financial Services Sub-

Committee. Simon was named as the Best Regulatory Lawyer of 2008 at Complinet’s Fourth Annual Compliance

Awards in January 2008.

Alison McHaffie

Partner – London Office, Financial Services Disputes

T +44 (0) 20 7367 2785

E alison.mchaffie@cms-cmck.com

Alison is a partner in the firm’s Financial Services Group. Since qualification in 1995 she has specialised in

advising firms and individuals in the financial services sector on contentious matters and has extensive experience

of acting for financial institutions and senior individuals in relation to FSA investigations and enforcement actions

covering a wide range of issues including governance, conflicts of interest, market abuse, financial crime controls,

transaction reporting and retail mis-selling. She also regularly advises firms on dealing with complaints before the

Financial Ombudsman Service and on dealing with FSA supervisory and thematic visits and s.166 Skilled Person

reports. In 1998 she was seconded to the Enforcement Division of the FSA.

Governance, Risk & Arrow

Simon Morris & Alison McHaffie

January 2012

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Looking at …

1. The new agenda for risk and governance

2. How will the new regulators view governance?

3. What is a model for risk management?

4. What must senior management do?

5. Preparing for and protecting against regulatory scrutiny

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1. The new agenda for risk & governance

Role of the PRA

– Seeking to ensure that the business of a PRA-authorised person is carried on to avoid any adverse effect on the stability of the UK financial system; and

– Seeking to minimise the adverse effect that the failure of a PRA-authorised person could have on the stability of the UK financial system.

Role of the FCA

– Protecting & enhancing confidence in the UK financial system

=> Increased focus on governance

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Focus on governance – a PRA firm

Delivering a judgement-based model of supervision

– Nature & intensity to depend on assessment of risk

– Forward focusing risk assessment: impact, probability & resolvability

• Financial strength & business risk

– Business model

– Capital & liquidity

• Risk management

– Governance

– Culture

• Management

– Risks

– Controls

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Focus on governance – an FCA firm

A new approach to conduct regulation

– Detailed business & market analysis

– Forward-looking assessment of potential detriment

– Focus on culture

– Increased regulatory contact for the largest firms

– Earlier intervention

=> Increased focus on governance

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2. How will the new regulators view governance?

“The key issue during the financial crisis was not a lack of governance rules but a lack of effective implementation of theserules”.

EBA guidelines on internal governance 9/11

– What does governance mean in 2012?

– What will the PRA & the FCA expect to see?

In deciding whether a firm has effective governance arrangements, the FSA looks at the design of its governance structure as well as any evidence of its practical operation

FSA Preliminary Investigation Report January 2012

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What does governance mean for a regulator?

Governance is the process of senior management

• Setting strategy

• Understanding risk

• Creating a control framework

PRA/FCA will want evidence of governance in action

• Identifying and managing risk

• Orderly decision taking

• Meeting regulatory requirements

Evidence calls for

• Quality of reporting & analysis

• Documentation & record keeping

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What does governance mean for a firm?

An active board

– Sets strategies & policies

– Receives appropriate information

– Oversees risk functions

Board oversees management

– Clear performance objectives

– Holds management to account

Suitable risk management

– Robust mechanism to identify & monitor risk

– Procedure to ensure compliance

– Robust risk function

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Elements of governance include

1. Clear governing documents

2. Risk-attuned strategy

3. Robust procedures and controls

4. Strong risk function attuned to business

5. Business grasps governance

6. Established corporate culture

7. Decision making and actions linked to this culture

All means to the end of good governance –

Board + management + risk

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What will a regulator ask?

– Show us the structure of your governance

– Show us the papers, the minutes & the evidence

– And then, show us how it works …

• How was the decision taken?

• How were conflicts handled?

• What alternatives were evaluated?

• How was the decision maker competent?

• Was the process orderly?

• Why was the exposure to risk acceptable?

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And four further drivers of good governance

1. An appropriate corporate structure

• Clarity

• Transparency

• Form follows function

• Comprehensible & capable of oversight

2. Management structure

• What is it?

• Board & committee appropriate terms of reference

• Reporting lines match legal & operational structure

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3. Clear organisational structure

• Clear & consistent lines of responsibility

– Does form follow function?

– Within a matrix, is there local information capture?

– Do you remember the NAB example?

• Is every task mapped & managed?

– Show us the business flows & risk maps

– Have you applied the “Soc Gen” test?

• Does it pass the “job description” test?

– This are my responsibilities

– This is to whom I report, with what information

– This is who reports to me, with what information

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4. Culture

Management must be satisfied that the firm’s culture is delivering the right

outcomes

• Prudence

• Risk alertness

• Remuneration

• Ethical tone

• Treating customers fairly

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3. What is a model for risk management?

1. Know your risks

• Risk = non-achievement of goal

• Negative impact on firm’s financial position, performance, reputation,

customers

• Liquidity – market – counterparty – operational ...

• Can you show a comprehensive risk mapping?

2. Adaptable and flexible

• Ensure comprehensive

• Reviewed periodically

• New products and strategies

• Can you show dynamic risk management?

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3. Management prepares a risk statement/matrix

• What are the risks?

• How are they managed or mitigated?

• How does this match the ICAAP/ILA?

• Can you demonstrate comprehensive overview of risk profile?

4. Suitable organisational framework – a 1st yield

• Defines and coordinates duties & responsibilities

• Separates incompatible functions – business types, or risk + monitoring,

initiation + settlement

• Identifies and manages conflicts

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5. Adequate risk management function – a 2nd yield

• Seniority, resources & independence

• Prepares procedures

• Monitors, assesses & reports, provides early warnings of risks and errors that generate risks

6. Each business unit – a 3rd yield

• Understands & owns its risks

• Documents its risk processes to the common standard

• Follows risk policies

• Submits to monitoring

• Provides adequate MI

• Takes appropriate remedial action

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7. Management oversees – a 4th yield

• Ensures consistent processes & documentation

• Assumes responsibility for

– Ownership of risk

– Authority to incur risks

– Approval of new risks

– Oversight of risk

• Receives and acts on the right MI

• Show me

– Conflicts

– Remuneration

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4. What must senior management do?

1. Discharge the overriding regulatory obligations

• Currently APER 1 – 7

2. Participate in the firm’s governance arrangements

3. Ensure their area is well organised and controlled

4. Identify and manage risks within their remit

5. Receive and act on MI

6. And constantly challenge

Because ...

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The board should

– Directors competent with spread of skills

– Who can challenge – and show me

– Promote right culture

– Evidence of effective governance

• Operations overseen

• MI received and actioned

• How major issue or development handled

• Performance objectives set & monitored

• Risk overseen

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The regulatory expectation of an executive is ...

Executive

–What did you know

–What did you do

–On what information

–Who did you ask

–How did you monitor

–What improvement?

Non-executive

–Did you know

–Did you understand?

–Did you attend

–What did you ask

–What did you hear

–What further challenge?

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And personally, and at all times ...

– Understand and can challenge what is happening

– Satisfied firm is identifying material risks which are being

• Monitored

• Managed

• Mitigated

– Firm’s strategy is based on understood risks

– Firm’s business matches strategy & risk appetite

– Management is getting the right information and acting on it

– Clear escalation of issues and clear lessons learned

– And that the culture is right

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5. Regulatory scrutiny – preparing & protecting

– The new agenda

– The new touch points

– Preparing

– And the continuing focus on senior management

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The Relationship Judgemental, Intrusive and Interventionist

– Judgmental

• A more challenging relationship with the regulator

• Judgements may differ from the firm’s view

• More skilled supervisors

– Intrusive and Interventionist

• Increased regulatory contact

• Forward looking assessment of potential detriment

• Earlier intervention:

– in the development of new products and distribution paths

– where threat to safety and soundness of a firm

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Potential consequences of a poor relationship

– “NO”

• No to the new product launch before forensic reviews

• No to the Part VII because of management stretch

• No to the new business because of instability of business model/potential customer detriment

• No to the proposed CRO/NED

– “YES”

• Yes to overhaul your systems & controls

• Yes to review past business

• Yes to requiring restructuring/disposal/new CEO

• Yes to Skilled Person appointments

• Yes to Enforcement action

– Against the firm

– Against its management

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Looking at the key areas of supervisory interaction ….

– Supervisory/thematic visits and ARROW equivalents

• The new PRA “close & continuous”

• The new FCA thematic & large firm concentration

– SIF Interviews

The model is still being determined, but in all cases preparation is vital to protect the firm and regulatory relationship

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What is the supervisory target?

– Risk + Governance +Senior management

– PRA firms and key FCA firms

– Periodic review of risks & controls

– Smaller less risky firms – thematic focus

– Key to firm’s relationship

• Determines overall intensity of regulatory approach

– Can trigger serious remedial action

• Remedial

• Looks to management to address

• Failure will be costly

– Intervention

– Capital

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And the design template for the new “ARROW”?

– “Central to its design ..will be simplicity and a recognition that the approach must be understandable not just to regulatory specialists but to boards as a whole” (Hector Sants 29 June 2011 on FCA)

– Replacing ARROW with new simplified framework for assessing risks

– Will identify a “core handful of issues” for management to focus on

– Same key risk elements:

• Impact – of firm coming under stress or failing

• Probability – looking at macroeconomic and business risk to viability

• Resolvability or mitigation – operational, financial and structural

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Preparing for a supervisory visit

1. Understand and identify the issues

2. Prepare

3. Manage

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The timetable

1. Notification of date of visit

2. Appoint project team (if not already in place)

3. Fulfil pre visit information request

4. Handle the visit

5. Seek debrief

6. Deal with resulting issues

7. Receipt of draft report

8. Acting on final report

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1. Understanding & Identifying key regulatory concerns – keeping ahead of the game

– FSA’s Financial & Retail Risk Outlook and Business Plan

– Corresponding PRA/FCA material

– Current regulatory developments

– Sector specific Issues

• ENF cases

• Dear CEO letters

• Consultation papers/ speeches

• General market knowledge

– Firm Specific Issues

• Last ARROW

• Recent dialogue with regulator

• Recent events impacting on risk/strategy

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2. Preparing for interview

– Reading pack

– Establish the “party line”

• Strategy & Business Plan

• Risk management

• Governance

• Known issues & weaknesses

• TCF

– Rehearse interviews

– Tips

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At the interview

1. Be accompanied

2. Read the papers & do your homework

3. Answer from your personal knowledge

4. Seek clarity on vague questions

5. Give clear brief answers

6. Think before you speak

7. Don’t accept PRA/FCA assertions unless correct

8. Don’t be drawn into controversy

9. Stay calm

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Six key messages to convey

1. I know my role

2. I challenge I do not rely

3. I know the strategy

4. I know the risks

5. I understand the management process

6. I understand the world in 2012

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3. Manage the visit

– Seek an agenda for interviews

– Note-taker at all times

– Daily de-briefings

– Befriend & enquire

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SIF Interviews – initial & ongoing

– “Our more intrusive approach continues to place a great deal of emphasis on governance and therefore senior management at firms”Dear CEO letter of October 2009

– Close vetting of SIF appointments:

- Focus on competence & capability

- Interviews of SIF candidates

- Questioning due diligence undertaken – not just references and credit

checks

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What will the regulator look for?

– Focus is on competence to do the job & it will examine:

• Past experience

• Market knowledge of the sector

• Understanding of the business strategy and model

• Ability to identify the risks the business is exposed to

• Ability to interpret and act on the firm’s financial information

• Understanding of the firm’s governance, oversight and controls

• Understanding of the regulatory framework and requirements

• Soft skills – are you a leader?

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A typical interview will cover

1. Experience, motivation and responsibilities

2. Looking inwards

a) Risk management

b) Governance

c) Current firm developments

3. Deep dive – your “special subject” – such as

a) TCF

b) Risk

c) Strategy

d) Liquidity

4. Looking outwards

a) Market developments

b) Resilience for change

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How SIFs will be judged

APER 5 – 7 [and their successors]

– Proper control – have you mapped the business & identified the risks?

• How did you manage them?

• How did you manage subordinates?

– Skilful Management – do you fully grasp it?

• What MI do you get?

• What do you do with it?

– Business is compliant – how is it monitored?

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And if management fails the test?

– A second chance - re-interview

– “NO”

• to the Applicant

• to the manager/director continuing in post

– Calls into question the firm’s judgement

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When does a regulator act against an executive?

1. Aware of breaches and failed to ensure firm took remedial action

2. Failed to ensure firm had robust systems and controls

3. Failed to undertake comprehensive review of risks firm faced

4. Failed to ensure systems in place to ensure suitability

5. Failed to take reasonable steps to ensure customer communications clear

6. Failed to escalate MI and misled management

Consequences include:

1. Substantial personal fines

2. Public censure (named and shamed)

3. Prohibited or suspended by the regulator

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Impact on senior management

– Increasing appetite to investigate the actions of senior management when investigating a firm’s failings

– Gradual increase in disciplinary action against individuals where no dishonesty but where individual failed to take reasonable steps to ensure the business is controlled effectively and meets regulatory standards.

– Impact:

• Supervisory approach more challenging of senior management

judgements

• Senior management more aware of expectations and requirements

• More challenges at RDC/Tribunal

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So in conclusion

1. Sound governance is the target

2. Governance = board + management + risk => strategy

3. Intensive supervision will highlight the fault lines – the focus will be on board + management + risk

4. PRA and FCA will probe management judgements

5. PRA and FCA will challenge unsatisfactory management

6. And will have an appetite for disciplining firms and their executives

ARROW assuranceAvoiding unpleasant surprises

Preparing for your ARROW visitOur 6 stage approach

Preparing the ground -briefing on ARROW process

Scoping and project plan

Document review for FSA request

Pre-interview preparation

Mock interviews

Feedback – FSA’s Risk Mitigation Programme

ARROW –FSA’s new approach

Sectoral issues including SCV and

client assets

Risk management

NED and executive interviews

Systems and controls

Governance

Capital and liquidity

Risk mitigation report and ICA

Strategy

probing competence

intrusive supervision

risk adverse judgement on

judgements

Document request

Business as usual review

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Preparing for ARROW visits and SIF interviews

We help firms prepare for ARROW visits (an FSA inspection visit). We also prepare senior executives and NEDs for SIF interviews. This document explains our approach to ARROW preparation – which is proactive rather than reactive. SIF interview preparation is a more limited task but we adopt a similar approach.

Our proposal

Our proposal will be tailor-made to your business and our knowledge of FSA’s current Arrow methodology. It will prepare you for a future Arrow visit, and additionally:

- Provide independent assurance and benchmarking of your regulatory compliance;

- Enable you to benefit from current best practice recommendations; and

- Ensure you are in tune with FSA’s current “tougher” approach not just in conducting Arrow visits but across a broad range of live issues, such as remuneration.

Our approach

We will replicate the current methodology used by FSA when performing an ARROW visit. ARROW is the name given to FSA’s biennial inspection visit to major “relationship managed” firms that focuses on their:

- Systems and controls;

- Risk management; and

- Governance.

We consider that the structure of the inspection visit should follow the ARROW format, which entails (i) requesting a set of documentation and procedures; (ii) interviewing senior staff on the basis of this material; (iii) advising the firm of remedial action that it is required to take.

Benefits for you The overall benefit of this review will be to give you and your senior officers assurance that:

- Your business will sustain an ARROW visit with no unpleasant surprises; and

- Your general compliance with FSA rules is satisfactory, and that any areas for improvement can be addressed in short order and with a minimum of difficulty.

Our expertise

We have undertaken six ARROW preparation projects in the past six months across the full range of financial services institutions including an international fund manager and a major retail bank. We are well-placed to assist you in identifying the documents FSA will require and to carry out a protective pre-visit review, to prepare directors and key personnel for their FSA interviews and to ensure that you are properly prepared for FSA’s visit.

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Our skills and experience in this area have encompassed many different sectors, clients and issues and means that we are in a position to hit the ground running, delivering value from day one. By drawing on our extensive expertise we will be able to provide you with specifically tailored guidance, advice and training to ensure you will have a sound understanding and will be fully prepared for all aspects of an FSA inspection.

What clients have said about our recent ARROW preparation work:

- I think an accountancy firm tend to do a lot more of the giving you great wedges of slides ...but not perhaps quite as specific as to current trends in the FSA, current hot topics that I think Simon particularly has his finger on the pulse of that I think was quite helpful – Head of Legal, Retail Bank

- They were also very able to answer specific challenges from some of the Executives as well in a way that was just very helpful, cut through the wiffle-waffle and made people sit up and take notice – Head of Legal, Retail Bank

- Simon was able to ascertain where I was uncomfortable and therefore I would take the action required to sort things. And there were other areas where he was kind of helping me see where I might want to think about things differently and I found that useful – Head of Risk, Retail Bank

- As it turned out the interview that CMS put us through was significantly more rigorous than anything the FSA came up with – Head of Risk, Retail Bank

Our role - helping you achieve your objectives

Our role is to help you ensure that you are fully prepared for its FSA ARROW visit on time and to cost. We will deploy our experience of advising on these issues to run the project efficiently and help you ensure that the business is ready and prepared in good time.

STAGE 1 – PREPARING THE GROUND

It is essential that all personnel involved in the project, particularly members of the Board, understand the aims and objectives of the ARROW visit, the process and what FSA will be looking for. We will therefore propose an initial Board presentation (which can be attended by anyone else you feel would benefit) setting out the ARROW process, tips for the interview, issues for you, focus on individuals and the new regulatory environment. This will be tailored to your business but to give you an idea of the type of presentation. As part of Stage 1 we will also provide you with our overview of the ARROW process tailored to your business.

STAGE 2 – INITIAL SCOPING AND PROJECT PLAN

We will work with you to ensure that your project plan covers all aspects you need to consider when preparing for your ARROW visit and that impetus is maintained up to the date the FSA visit starts. The project plan will, of course, need to be specifically tailored to your business. We have a template project plan that we regularly use when assisting clients. You may wish to use this as the basis for your own project plan or as a “sense check” against your existing project plan.

STAGE 3 – THE FSA DOCUMENT REQUEST

We can help you to identify the documents that FSA are likely to request from you. This will enable you to carry out a protective review of the documents to ensure that you have them all ready for production, that version control is in place and that action is taken to address any issues identified before the FSA request is made. We can provide a list of the likely documents.

STAGE 4 – INDIVIDUAL PRE-INTERVIEW PREPARATION

It is important that all those being interview by FSA are aware of current regulatory concerns attaching to your business. We will therefore prepare a tailored reading list together with a note detailing the key themes and explanatory notes to enable your senior management team to ensure that they are able to deal with any questions raised by FSA during the interview process on regulatory developments affecting your business.

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STAGE 5 – INTERVIEW PREPARATION

We will carry out “mock” interviews with each person due to be interviewed by FSA. Drawing on our significant experience in dealing with such matters, we will spend between one and two hours with each person, asking the questions that FSA is likely to ask in relation to that person’s role and responsibilities within your organisation. At the end of each interview we will carry out a de-brief and where necessary highlight those areas where further preparation is required by the individual. Sometimes it is necessary to carry out a second interview, but this is rare. An interview grid is prepared for each individual interview and is based on a review of the documents provided to FSA as a result of the document request.

STAGE 6 – FEEDBACK

We provide you with immediate briefings of what is said – and not said – during mock interviews to help you to identify and manage any areas of weakness or inconsistency.

These are our suggested stages and represent a framework that we have successfully used with a number of firms. You may want to adopt this approach or, alternatively, you may wish to tackle your project in a completely different way. However you want to proceed, we can use our significant experience of preparing firms to enable you to achieve the optimum result and we look forward to discussing your approach and requirements with you.

After the visit

After FSA has undertaken its visit we will work with you to assess the outcomes including, where relevant, any additional work to be undertaken under a Risk Mitigation Programme.

Our team Demonstrating our capabilities

A selection of our relevant ARROW experience undertaken over the past six months: Preparing the UK branch of an overseas wholesale bank for its ARROW visit in July/August last year where FSA had concerns relating to its fraud and anti money laundering controls. FSA was seeking to extend its ARROW review well beyond the remit of that appropriate for a BCD-passported firm. Our focus was on ensuring that the bank resisted regulatory creep while satisfying FSA that matters were being dealt with appropriately and that the firm should not be referred to enforcement – in which we succeeded.

Preparing a major retail bank for its ARROW visit in August/September last year where the particular focus was on Treating Customers Fairly and business strategy to start deposit-taking and offering mortgages. This work included briefing each member of the Board including all non-executive directors and a number of key personnel. In this case, FSA particularly focussed on the banks’ treasury operations and use of the ICAAP and the resulting RMP contained no issues with which the bank was not already dealing.

Preparing an international fund manager for its ARROW visit in October last year. This included preparing those responsible for international offices in Europe and Asia with particular reference to outsourced arrangements where concerns had been raised. The client felt particularly vulnerable in relation to the matter of remuneration and incentives and our preparation ensured that all key personnel were properly able to deal with the questions raised by FSA on this core issue.

Preparing a mono-line credit card issuer and bank for its ARROW visit in November last year. This firm has been subject to previous enforcement action by FSA in relation to sales of PPI and it was therefore critical that the firm and its management were able to demonstrate that business was being dealt with in strict compliance with FSA requirements.

Preparing the Board of a mutual insurer for its ARROW visit in December last year, covering the key issues of strategy and board effectiveness.

Assisting the insurance arm of a major UK charity in its preparations for an anticipated ARROW visit over the next few months, in particular dealing with issues arising from the unsanctioned holding of client monies throughout a significant branch network.

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Our commitment on fees

In this economic climate, we want to ensure we provide you with a service that is value for money and can provide you with cost certainty.

We can discuss alternative fee arrangements with you. We can provide you with one or more cost estimates for the entire project based on alternative arrangements and discuss this with you further.

Simon Morris CMS Cameron McKenna February 2010

A Timeline for Reform – 12 January 2012

Key

Blue Domestic UK measures

Violet European/EU measures

Green International measures

NYP (expected prior to end 2011)

December Rescue & Restructure – EC to publish Guidelines for rescue and restructuring of financial institutions to ensure continuity when present rules expire. (Link to Commission Legislative Proposals list)

December Financial Penalties – EC to publish proposal on Regulation for mutual recognition of financial penalties. (Link to EU 2011 Programme)

Q3 2011 Innovative Financial Instruments – ECOFIN to publish communication on innovative financial instruments for the new Multi-Annual Financial Framework. (Link to EC Commission 2H 2011 programme)

Q4 2011 With-Profits & Unit-linked Funds – FSA to publish consultation paper on proposed amendments to take Solvency II into account. (Link to FSA Business Plan 2011/2012)

Q4 2011 Compensation – FSA to publish consultation paper on Compensation Review. (Link to FSA Business Plan 2011/2012)

Q4 2011 Credit Unions – FSA to publish review of Credit Unions sourcebook, finalising near-final rules in PS10/11. (Link to Policy Development Update, No. 137, July 2011)

Q4 2011 Credit Unions – FSA to publish Regulatory Guide for Credit Unions (CURG), a new guide. (Link to Policy Development Update, No. 137, July 2011)

Q4 2011 Pensions – EC Commission to publish white paper on pensions. (Link to EC Commission 2H 2011 programme)

Q4 2011 Solvency II – EC to introduce calculation of new Solvency II risk sensitive capital requirement as well as the level 2 technical measure. (Link to EU 2011 Programme)

Q4 2011 Financial Sector Sanctions – EC to publish approximation of financial sector sanctioning regimes. (Link to Commission Legislative Proposals list).

Q4 2011 Retail products – Packaged Retail Investment Products legislative proposals to be introduced. (Link to EU 2011 Programme)

Q4 2011 Assignment – EC Commission to report on effectiveness of assignments and the priority of assigned claims. (Link to EC Commission 2H 2011 programme)

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End 2011 Deposits – revision of Deposit Guarantee Schemes Directive expected to be completed. (Link to the European Commission’s financial reform programme)

End 2011 Securities Law – EC Commission to publish Securities Law Directive. (Link to European Parliament DG Internal Affairs Economic & Scientific Workshop on Securities Law Directive)

End 2011 Derivatives – Legislation on market infrastructure expected. (Link to the European Commission’s financial reform programme)

End 2011 Solvency II – Implementing measures for Solvency II Directive on capital requirements for insurance undertakings to be agreed on. (Link to the European Commission’s financial reform programme)

End 2011 Financial reporting – new revised framework (FINREP rev3) will be published.

End 2011 Accounting – international accounting bodies, including FASB and IASB, to complete their convergence project for a single set of global accounting standards. (Link to G20 Progress Report)

Timeline

2012

13th January MiFID: Deadline for responses to consultation based on questionnaire to inform ECOFIN’s work on MiFID II. (Link to Questionnaire)

13th January PPI – deadline for responses to FSA guidance on new PPI products. (Link to guidance)

16th January RDR adviser charging – legacy assets – deadline for responses to CP 11/26. (Link to consultation)

18th January Non-executive directors – deadline for responses to FSA consultation on the role of non-executive directors. (Link to consultation)

20th January Bank recapitalisation – banks to submit their plans for compliance with EBA recommendations on capital positions to their national authorities. (Link to EBA recommendations)

20th January Own risk and solvency assessment – deadline for responses to EIOPA consultation on proposal for guidelines. (Link to consultation paper)

20th January Narrative public disclosure- deadline for responses to EIOPA consultation on draft proposal.

(Link to consultation paper)

20th January Quantitative reporting templates - deadline for responses to EIOPA consultation on proposal. (Link to consultation paper)

23 January Traded life policy investments – deadline for responses to FSA guidance consultation. (Link to consultation)

26th January Debt collection – deadline for responses to OFT guidance on the recovery of consumer credit debts. (Link to OFT guidance)

27th January Regulated covered bond regime – deadline for responses to FSA guidance consultation. (Link to guidance consultation)

27th January Packaged bank accounts – deadline for comments on FSA CP11/21. (Link to consultation paper)

30th January Distributor-influence funds – deadline for responses to FSA guidance consultation. (Link to consultation paper)

31st January Alternative Dispute Resolution – deadline for responses to BIS call for evidence on EU proposals. (Link to call for evidence)

3

31st January Complaints handling for insurers – deadline for responses ton consultation paper and draft report on best practices. (Link to the consultation and draft report)

January CRD IV – EP to produce draft report on bank capital requirements. (Link to press release)

January FATF Standards – plenary meeting planned to finalise text of new Financial Action Task Force standards. (Link to summary of October meeting)

13-16 February Omnibus II – Plenary session during which the European Parliament will consider the proposed Omnibus II directive

20th February FSA budget – deadline for responses to FSA Plans and Budget for 2012/2013 document. (Link to publication)

2nd February Credit rating agencies – deadline for written submissions to the Treasury Select Committee concerning their inquiry into credit rating agencies. (Link to press release)

3rd February Consumers in retirement income – deadline for responses to ABI consultation on proposed compulsory code of conduct for communications by retirement income product providers. (Link to consultation)

3rd February OFT – deadline for responses to annual plan consultation document. (Link to paper)

6th February FSA – deadline for responses to FSA CP 11/27. (Link to consultation paper)

6th February Regulatory fees and levies – deadline for comments on chapter 2 of CP11/21. (Link to consultation paper)

10th February Acquisitions directive – deadline for responses to EC consultation on the directive, specifically its provisions in relation to the acquisition and increase of holdings in the financial sector. (Link to EC consultation paper)

10th February Instruments of macroprudential policy – deadline for responses to Bank of England/FSA discussion paper analysing the macroprudential tools discussed by the Financial Policy Committee in September 2011 meeting. (Link to discussion paper)

14th February Bank executive remuneration disclosure – deadline for responses to government consultation on regulations requiring large UK banks to publish pay details of their highest paid senior executives. (Link to consultation)

14th February Prudent valuation – deadline for response to FSA consultation on amending requirements on quarterly reports showing differences between prudent and fair valuation. (Link to consultation paper)

15th February Transposition of Solvency II – deadline for comments in response to FSA CP 11/22 and 11/23. (Link to CP 11/22 and CP 11/23)

15th February Solvency II – deadline for responses to HMT consultation on implementation of Solvency II. (Link to consultation)

17th February Capital disclosure – deadline for responses to BIS proposed definition of capital disclosure requirements. (Link to BIS proposals)

17th February Credit risk and derivatives – deadline for responses to BIS consultation paper on the application of elements of BASEL III to fair valued derivatives. (Link to consultation paper)

20th February Quantitative reporting templates – deadline for responses to EIOPA consultation on proposal for quantitative reporting templates for financial stability purposes. (Link to consultation)

24th February ESMA/MiFID – Deadline for responses to ESMA consultation paper on MiFID suitability requirements. (Link to consultation paper)

24th February ESMA/MiFID – Deadline for responses to ESMA consultation paper on MiFID compliance function requirements. (Link to consultation paper)

4

29th February Insurance benefits/premiums – deadline for responses to HMT consultation paper on ECJ ruling on gender neutrality of benefits/premiums. (Link to consultation paper)

February FATF Standards – implementation date for new Financial Action Task Force standards. (Link to summary of October meeting)

February Insurance mediation – EC to adopt revised Insurance Mediation Directive. (Link to BIPAR articles, with link to interview with Karel Van Hulle, July 2011)

February PRIPS – EC to adopt PRIPS proposals. (Link to press article reporting dates)

February Payments council – Report due on governance and performance assessment. (Link to review)

February BERR/BIS: The Kay review of UK equity markets – Interim report to be published

Early 2012 Money-Laundering – EU Financial Action Task Force (FATF) due to report. (Link to ABI update with link to AML update)

Early 2012 Financial market infrastructure – BIS/IOSCO final report to be published. (Link to BIS/IOSCO Consultation Paper) (Link to responses)

2nd March Internal audit function in banks – deadline for responses to Basel Committee on Banking Supervision consultation document. (Link to consultation)

6th March Advanced Measurement Approach – deadline for competent authorities to apply EBA guidelines on the AMA extensions and changes. (Link to guidelines)

9th March Deposit protection – deadline for responses to FSA consultation paper on requirements for deposit takers to display their deposit protection arrangements prominently to customers. (Link to consultation paper)

13th March Prospectus and transparency directive – deadline for responses to FSA consultation paper on the UK implementation of this amending directive. (Link to consultation paper)

16th March Financial conglomerates – deadline for responses to BIS proposed principles for supervision of financial conglomerates. (Link to BIS proposals)

20th March Banking supervision – deadline for responses to BIS consultation on core principles for effective banking supervision. (Link to consultation)

20th March Supervisory reporting requirements –deadline for responses to EBA consultation on draft implementing technical standards on supervisory reporting requirements for institutions. (Link to consultation)

23rd March Pensions – deadline for responses to Department of Work and Pensions consultation on improving transfers and dealing with small pension pots. (Link to DWP guidance)

30th March Solvency II (Internal Models) – date on which FSA plans to open applications for internal models approvals process (IMAP). (Link to FSA (Julian Adams) speech, 18 April 2011)

31st March Internal governance – European Banking Authority expects competent authorities to implement guidelines on internal governance and incorporate them within their supervisory procedures. (Link to EBA Guidelines on internal governance)

31st March Northern Irish Credit Unions – date from which these will need to be authorised by FSA.

31st March Market Conduct and Transaction reporting – date from which FSA guidance takes effect. (Link to market newsletter)

March OTC Derivatives Regulators’ Forum – Next formal meeting of ODRF scheduled to be held in Hong Kong

Q1 2012 Money Laundering Regulations – HMT to publish response to consultation on proposed changes to regulations. (Link to consultation)

5

Q1 2012 Capital Requirements – FSA to publish consultation paper on CRD 4. (Link to FSA Business Plan 2011/2012)

Q1 2012 Mortgage Market Review – FSA to publish policy statement. (Link to FSA Business Plan 2011/2012)

Q1 2012 With-Profits – FSA to publish PS to CP 11/5 on protecting with-profits policyholders. (Link to FSA Policy Development Update November 2011)

Q1 2012 Common Reporting – FSA to publish policy statement on Guidelines on Common Reporting (COREP). (Link to FSA Policy Development Update November 2011)

Q1 2012 Recovery & Resolution – FSA expects to issue Policy Statement on Recovery & Resolution. (Link to FSA Policy Development Update November 2011)

Q1 2012 Common Reporting – FSA to publish consultation paper on COREP common reporting rules. . (Link to Policy Development Update, No. 136, June 2011)

Q1 2012 Markets Risk Outlook – FSA to publish markets risk outlook paper. (Link to FSA Milestones Update, August 2011)

Q1 2012 Compensation Review – FSA to publish paper. (Link to FSA Milestones Update, August 2011)

Q1 2012 Client assets – FSA to publish PS to CP 11/15 on Client Assets sourcebook (Link to FSA Policy Development Update)

Q1 2012 Code of practice for insurers – ABI to introduce a compulsory code of practice for insurers, developed in conjunction with its members. (Link to ABI news release)

Q1 2012 UCITS V – EC to publish amendments to UCITS directive as regards rules on UCITS depositaries and remuneration policies (delayed from Oct 2011). (Link to EU legislation programme 2011)

Q1 2012 Short selling – regulation on short selling/credit default swaps expected, along with Technical Standards, Technical Advice, Guidelines and Recommendations thereon from ESMA. (Link to ESMA 2012 work programme)

Q1 2012 IMD – EC to publish IMD directive text. (Link to ABI update with link to IMD & PRIPS report)

Easter HMT – Treasury to publicly present an analysis of their response to the financial crisis to executive management board. (Link to press release)

6th April Pensions – new rules on Pension Scheme Disclosures to come into force. (Link to FSA Consultation Paper 11/03)

16th April FSA case fees – deadline for responses to “Charging for our work: modernising our case fee arrangements from 2013”. (Link to publication)

24th April Transaction reporting system – date on which the contacts TRS users have with the FSA for TRS reporting will terminate. (Link to FSA letter)

30th April Non-EU Credit ratings – ESMA’s revised end of transitional period for use of credit ratings issued outside the EU. (Link to press release)

April PPI – remaining elements of remedies package (other than those on provision of information in marketing materials and to third parties) to come into force. (Link to CC timetable)

April CRD IV – Vote in ECON on bank capital requirements expected. (Link to press release)

April Prospectus Directive – Amending directive designed to reduce burden on insurers to come into effect. (Link to FSA Business Plan 2011/2012)

Spring Financial crime – The Law Commission to present its final recommendations (following responses received on consultation paper no. 195) to Parliament on the use of criminal law in regulatory contexts.

6

1st May Trading platforms – Projected effective date of guidelines on systems and control in automated trading environments for trading platforms, investment firms and competent authorities.

30th May Solvency II (Internal Models) – date on which FSA plans to close applications for internal models approvals process (IMAP). (Link to FSA (Julian Adams) speech, 18 April 2011)

18th June Recognised Auction Platform Regulations – date regulations (other than 6, 10 and Schedule 1) come into force. (Link to legislation)

30th June UCITS funds – deadline for firms to introduce the key investor information documents for their UCITS funds. (Link to FSA policy statement on transposition of the revised UCITS directive)

End June Bank recapitalisation – date by which banks are to have exceptional and temporary buffer of Core Tier 1 capital ratio of 9%, in line with EBA recommendations. (Link to EBA recommendations)

H1 2012 FSCS funding review – to consult formally, lead by Sheila Nicoll and looking at issues such as composition of the nine funding classes, levy thresholds applicable to each and their tariff bases. (Link to FSA press release)

July BERR/BIS: The Kay review of UK equity markets – Final report to be published

July HMT – Steering group on simple financial products to report back to the financial secretary to the Treasury. (Link to press release)

July Shadow banking – Workstreams setup by FSB in key shadow banking areas to report progress and policy recommendations. (Link to FSB press release)

1st July Short selling and CDS – European Regulation on short selling and certain aspects of credit default swaps to come into effect. (Link to Draft Regulation)

Summer 2012 Tax Transparent Funds – regulations to come into force. (Link to HM Treasury Press Release)

Q3 2012 Capital Requirements – FSA to publish Policy Statement on CRD4. (Link to FSA Business Plan 2011/2012)

Q3 2012 OTC derivatives – ESMA to publish Technical Standards, Technical Advice, Guidelines and Recommendations. (Link to ESMA Business Plan 2011/2012)

Q3 2012 IORP Directive – EU Commission to publish revised IORP Directive. (Link to ABI update with link to IORP Review)

1st October Pensions – amended conduct of business rules come into operation. (Link to FSA Policy Statement 11/08)

1st October Corporate governance – (subject to consultation) revisions to the UK Corporate Governance Code and the UK Stewardship Code to take effect. (Link to FRC paper)

1st October Self invested personal pensions – date from which firms may take advantage of rule for generic key features illustrations for groups/sub-groups of employees in group personal pension scheme. (Link to PS 11/14)

24th October BIPRU 12.9.13R – date until which this BIPRU rule concerning the implementation of contingency plans may be modified by consent (unless the rule itself is amended before this point). (Link to FSA guidance)

Autumn 2012 Computer trading – BIS to publish final report on the future of computer trading in financial markets. (Link to BIS working paper)

Autumn 2012 Insurance Guarantee Schemes – EC to publish Directive on insurance guarantee schemes. (Link to EU 2011 Programme) (Link to ABI page with link to IGS update with new timetable)

1st November Solvency II – new regime takes effect (possibility of date being put back to 1 January 2013). (Link to European Timeline chart produced by FSA)

November Short selling and CDS trading – new EC regulation to enter into force. (Link to press release)

7

21st December Insurance – derogation from EC Directive, allowing gender-based insurance premium differences, to end from this date. (Link to ECJ Press Release)

31st December RDR Adviser Charging – new rules on RDR Adviser and Consultancy Charging requirements to come into force. (Link to FSA Consultation Paper 11/03)

31st December Retail reporting – changes to Retail Mediation Activities Return and data collection based on RDR rules on adviser charging and professionalism to come into force. (Link to FSA consultation paper)

31st December Self invested personal pensions – new disclosure rules for SIPPs come into force. (Link to PS 11/14)

31st December Reporting – Deadline for FSA and financial firms to apply COREP common European reporting standards. (Link to ESMA Business Plan 2011/2012)

Q4 2012 MiFID II – ESMA to produce Technical Advice, Guidelines and Recommendations. (Link to ESMA Business Plan 2011/2012)

Q4 2012 UCITS V/Venture Capital/Social Investment Funds - – ESMA to produce Technical Advice. (Link to ESMA 2012 work programme)

Q4 2012 AIFMD, UCITS, PRIPS – ESMA to produce Technical Standards in relation to all of these directives. (Link to ESMA 2012 work programme)

2012 Retail finance – OFT to conduct a review of the market in 2012 to analyse the impact of the initiatives introduced by personal current account providers.

2012 Accounting – global accounting standards to be implemented. (Link to G20 Progress Report)

2012 Prudential regulation – revision of the Financial Conglomerates Directive. (Link to the European Commission’s financial reform programme)

End 2012 Financial Services Bill – Financial Services Bill to receive Royal Assent. (Link to Hansard timetable announcement)

End 2012 Card surcharges – Government to implement forthcoming EU legislation to ban excessive surcharges on all forms of payment. (Link to press release)

End 2012 OTC derivatives – European Regulation on OTC derivatives, central counterparties and trade repositories to take effect. (Link to Europa press release)

End 2012 REMIT – REMIT to come into force (Link to European Parliament press release)

End 2012 Recovery and resolution – EC to publish proposals on harmonisation of national insolvency regimes. (Link to EC consultation paper)

End 2012 FSMA 2000 (Carrying on Regulated Activities by way of Business) (Amendment) Order 2011/2304 – HMT required to review the operation and effect of the amendment and publish a report before end of 2012.

2012/2013 MMR – Arrears and Approved Persons - FSA to publish final rules for CP10/2 (PS10/9. (Link to Policy Development Update, No. 137, July 2011)

2013

1 January Demise of the FSA – FSA to be fully wound up, supervision of banks to be carried out by the prudential regulatory authority, a legally separate but subsidiary part of the Bank of England that will replace the FSA by this time. (Link to HMT press release); (Link to FSA Business Plan 2011/2012)

1st January Regulated covered bonds – new FSA rules on regulated covered bonds come into force. (Link to FSA policy statement)

1st January Financial reporting – application date for FINREP v3

8

1st January Accounting – IFRS 9 (Financial Instruments) on classification and measurement of financial assets to take effect. (Link to G20 Progress Report)

1st January Capital and liquidity – deadline for national legislation implementing Basel III framework. (Link to BIS press release). (Link to Financial Stability Board report)

1st January Regulated Covered Bonds (Amendment) Regulations – date regulations come into force. (Link to regulations)

1st January RDR – changes with regard to adviser remuneration commission structure and training and qualifications to take effect. (Link to FSA Press Release)

22nd July AIFM Directive – implementation date across Europe for AIFM directive. (Link to FSA Business Plan 2011/2012)

30th September Credit Unions – capital-to-assets and liquidity requirements will be phased in and will take full effect on this date. (Link to FSA PS 10/11 ‘A review of the Credit Union sourcebook (CRED)’)

2013 Economic Crime – National Crime Agency, including Economic Crime Unit, to be fully operational. (Link to Home Office Paper, 8 June 2011)

2013-2014 Insurance Mediation Directive – planned implementation date across Europe for IMD

2014

1st January Solvency II – proposed date for insurers to become subject to Solvency II regime. (Link to European Council Presidency Compromise text, June 2011)

1st January Securitisation – 5% retention requirement to apply to new exposures under existing securitisations under CRD 2. (Link to CRD2)

1st January Transaction tax – Proposed date for EC transaction tax to come into effect. (Link to proposal)

31st December Market abuse – sunset clauses in s118 FSMA will cease. (Link to extending statutory instrument)

End 2014 Consumer Rights – target date for Dept of Business, Innovation & Skills to introduce Consumer Bill of Rights implementing Consumer Rights Directive (Link to department's timeline)

2015

1st January Capital and liquidity – proposed implementation date for Liquidity Capital Ratio requirements (new international standards must be met by this date). (Link to BIS Basel III December 2010 paper)

End 2015 Liquidity – full implementation of the Simplified Liquidity Adequacy Standards (ILAS) Regime. (Link to FSA Handbook Notice)

2018

1st January Capital and liquidity – proposed implementation date for Net Stable Funding Ratio requirements. (Link to BIS Basel III December 2010 paper)

2019

1st January Basel III – Basel III to be fully phased in. (Link to Financial Stability Board April 2011 report)

Up to date as at 12 January 2012.

Countdown to the new UK regulatory regime – PRA and FCA

10 January 2012 edition

Key

Blue Future

Violet Historic

News update

19th

December The Joint Committee on Draft Financial Services Bill published its first report and the results of its call for evidence

19th

December HM Treasury publishes its response to the Independent Commission on Banking report.

Timeline

2012

Early - Mid 2012 The interim FPC will report to the government for a second time, after its meeting in the first quarter of 2012 (expected to coincide with committee-stage consideration in the House of Commons).

The Second Reading usually takes place no earlier than two weekends after the First Reading, and the Committee Stage typically starts within a couple of weeks thereafter. Following the briefer Third Reading, the Bill will make its passage through the House of Lords. Parliamentary timetable to be announced. (Link to Parliamentary factsheet)

By end 2012 Financial Services Bill is expected to receive Royal Assent. (Written Parliamentary Answer on Timetable, 6 July 2011)

2013

1 January The formal cutover, from the FSA to the PRA, FCA, and FPC, is expected to take

place. The new regulatory system will operate under the amended Financial Servicers and Markets Act 2000.

2

2011

By end 2011 First Reading of the Financial Services Bill. Parliamentary timetable to be announced. (Written Parliamentary Answer on Timetable, 6 July 2011)

19th

December Publication of Government response to Vickers Report

16th

December Deadline for Joint Committee on the FS Bill to report on the draft Bill

1 December Completion of pre-legislative scrutiny of the Financial Services Bill. Joint Committee of Lords and Commons to report. (Link to Parliamentary Resolution establishing Joint Committee)

23 November Third meeting of the Interim FPC.

10 October Deadline for responses to the publication of terms of reference for the Treasury

Select Committees’ inquiry into FCA (Link to TSC announcement)

Autumn 2011 Treasury Select Committee to report on its inquiry into the accountability of the Bank of England. (Link to Treasury Press Release)

20 September Second meeting of the Interim FPC (Link to Bank of England Interim FPC website)

12 September The ICB will release its final report. (Link to ICB press release, following 1 August meeting)

8 September Deadline to respond to HM Treasury’s June 2011 White Paper (HM Treasury: A

New Approach to Financial Regulation, June 2011)

First sitting of the Joint Committee on draft Financial Services Bill: 9.35 am. Witnesses: TBC. (Link to Parliamentary Calendar)

2 September Deadline to respond to Joint Committee’s call for evidence on Financial Services Bill

(Joint Committee Call for Evidence, 20 July 2011)

1 September Deadline to respond to the FSA’s paper: FCA Approach to Regulation, June 2011

17 August Treasury Select committee officially launched its inquiry into the accountability of the FCA. No press release has yet been published. (Link to FT Advisor article)

18 July Joint Committee of Lords and Commons appointed to scrutinise Financial Services Bill. Membership is as follows: Rt Hon Peter Lilley MP (Chairman), Rt Hon Nicholas Brown MP, Baroness Drake, Rt Hon David Laws MP, Lord Maples, Lord McFall of Alcluith, David Mowat MP, Mr George Mudie MP, Lord Newby, Mr David Ruffley MP, Lord Skidelsky, Baroness Wheatcroft.

(Link to Parliamentary Resolution establishing Joint Committee)

July HM Treasury published a consolidated version of the Financial Services and Markets Act 2000 as amended by the Financial Services Bill 2011. (Link to Consolidated Version of FSMA 2000 as amended by FSB 2011)

June The FSA published a paper setting out its initial thinking on the FCA's approach to regulation. (Link to paper)

June The Bank of England and the FSA published a paper on the PRA's approach to insurance supervision (Link to paper)

16 June HM Treasury published draft Bill in White Paper: ‘A New Approach to Financial Regulation: the Blueprint for Reform’. Responses are requested by 8 September

3

2011. (Link to White Paper)

16 June Interim Financial Policy Committee held its first meeting. The interim committee is made up of 13 members including governor Mervyn King, deputy governor for financial stability Paul Tucker, Financial Services Authority chairman Lord Turner and FSA chief executive Hector Sants. (Link to Bank of England IPC website)

May The BoE and FSA published a joint paper on the PRA's approach to regulated deposit-takers and certain investment firms. (Link to joint paper)

April The FSA moved to its new management structure. Risk and Supervision units were replaced with a Prudential Business Unit and a Conduct Business Unit.

February HM Treasury presented further detailed policy proposals in consultation document: ‘A new approach to financial regulation: building a stronger system’

2010

November The Government published a summary of responses in 'A new approach to financial regulation: November 2010 summary of consultation responses.’

July HM Treasury published 'A new approach to financial regulation: judgment, focus and stability': to gather views on the proposals to reform the UK's financial regulatory framework, provide the Bank of England with control of macro-prudential regulation and oversight of micro-prudential regulation. The consultation period ran from 26 July to 18 October 2010.

Last updated 10 January 2012 Last updated: 17 August 2011 UK - 67087844.6

EU Commission’s Financial Services Proposals

Initiatives for Commission Adoption and Agreement

Initiatives and Key Dates for Commission Adoption and Commission Proposals for Endorsement by the Council and European Parliament The table below represents the forthcoming proposals on financial services regulatory reform from the Commission, which were released as part of its Commission’s Work Programme for 2011. The schedules of these proposals have been updated following the release of the EC’s overview of proposed financial services legislation in February and other announcements. The table contains the key dates for the adoption of proposals and proposed dates for the endorsement by the Council and European Parliament together with dates for non-legislative proposals. For more information, please also refer to our commentary on ‘The new European System of Financial Supervision’, which includes analysis on the impact of the new legislation below.

Initiatives Detail and Dates Useful Links Access to Minimum Basic Banking

Initiative on access to minimum basic banking services

A consultation was held in late 2010 and the Commission published responses to the Consultation Paper in February 2011. Commission dropped majority of its initiatives in this area in June 2011. Recommendation on access to basic account announced 18 July 2011.

EU Commission Consultation Paper, Oct 2010 Press Release on Commission's Backing Down, 22 June 2011 EU Commission Press Release, 18 July 2011

Single Market Act

The Single Market Conference took place in Brussels on 8 February 2011. Consultation on The Single Market Act closed on 28 February 2011. The Commission published its Single Market Act: 12 Levers paper on 13 April 2011 EESC published its response to Single Market Act proposals on 3 May 2011 The EC Council launched its conclusions and listed priorities on 12 July 2011

A New Strategy for the Single Market, May 2010 Public Consultation on Single Market Act Overview of Responses to Consultation Commission's Paper: Single Market Act: 12 Levers More information on The Single Market Act European Economic and Social Committee Response Council Conclusions on the Single Market Act, 12 July 2011

Alternative Investment Fund Managers Directive

Directive Text published 13 May 2011 EP approval 27 May 2011 AIFM Directive adopted 1 July 2011

Directive Text, May 2011 Directive text (Official Journal) ESMA Consultation Paper, July 2011

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Alternative Investment Fund Managers Directive

ESMA issued consultation paper on 14 July 2011 on all aspects of level 2 implementing measures in the directive save for those covered by the consultation paper detailed below. Responses were due by 23 September 2011. A public hearing was held on 2 September 2011. ESMA issued a consultation paper on 23 August 2011 on supervision and third country entities in respect of AIFMD, an open hearing on which was held 26 September 2011. Technical advice from ESMA was published on 16 November 2011. Responses to a previously released draft of this advice were published on 14 September 2011. The AIFM Directive should be transposed into national law and applied by Member States by May/June 2013.

Speech at AIMA Forum Commission's Homepage for AIFM Directive RegZone Report on AIFM Directive FSA AIFMD Directive Summary Responses to draft technical advice from ESMA to EU Commission Technical advice to the European Commission

Audit Policy

Consultation on Audit Policy – Lessons from the Crisis

EU Commission consulted on whether audits provide all necessary information and whether supervision at European level would be useful. Responses and Green Paper published February 2011. EP legal affairs committee approved Green Paper on 24 May 2011 Proposal for a regulation on specific requirements regarding statutory audit of public-interest entities published, 30 November 2011

Consultation Paper Commission Green Paper Link to EBA Letter commenting on audit implications of IAASB financial reporting proposals, 1 June 2011.pdf Proposal for a regulation on specific requirements regarding statutory audit 30 November 2011

Capital Requirements (also see Solvency II)

Revision of the Capital Requirements Directive

CRD III (covering amendments addressing capital requirements for the trading book and re-securitisation, disclosure of securitisation exposures, and remuneration policies) came into force on 1

January 2011.

Commission consultation on capitalisation of bank exposures to central counterparties closed 9 March 2011 The legislative proposal to transpose Basel III into EU law (CRD IV) published 20 July 2011 Capital requirement rules under Capital Requirements Directive to come into effect by end 2011. Draft European Parliament report on

Consultation Document for Revision of Capital Requirements Directive Commissioner Barnier's statement on Basel III and Capital Requirements Directive EP Financial Services Committee CRD IV Briefing Paper ECB presentation on Basel III and the Real Economy Consultation Paper on Capital Requirements re Counterparty Risk EP press release EU Commission FAQ on CRD IV, 20 July 2011

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transposition of Basel III expected in January 2012. Vote in Economic and Monetary Affairs Committee expected at the end of April.

RegZone Article on Capital Requirements FSA Capital Requirements Directive Summary

Corporate Governance

Corporate Governance in Financial Institutions

Consultation on Corporate Governance in Financial Institutions closed September 2010. Green Paper consultation on Corporate Governance generally closed 22 July 2011. EP non-legislative resolution on Corporate Governance in Financial Institutions, 11 May 2011

Green Paper on Corporate Governance in Financial Institutions Summary of Responses to Green Paper Commission Homepage on Corporate Governance in Financial Services Institutions RegZone’s homepage on Corporate Governance in Financial Institutions European Corporate Governance Forum EP Report, March 2011 EP non-legislative resolution on Corporate Governance, 11 May 2011

Credit Rating Agencies

Revision of Credit Rating Agencies Regulation (EU-level supervision of CRAs)

The new EU regulatory framework for Credit Rating Agencies came into force on 7 December 2010. Credit Rating Agencies’ registration and supervision now by ESMA. ESMA published consultation paper on endorsement of third country CRAs on 18 March 2011. Final report on consultation published 18 May 2011 CRA II published 11 May 2011 Further amendments to the CRA regulation expected in Q4 2011. ESMA has signed a co-operation agreement with Japanese FSA re supervision of credit rating agencies EP resolution: Credit Rating Agencies, Future Perspectives, 8 June 2011 ESMA published consultation paper on information to be provided to it by credit rating agencies under regulation, 19 September 2011 and has published the responses received Further proposal expected by end 2011 to address lack of competition and sovereign debt ratings. ESMA produced a list of registered and certified CRAs on 6 January 2012

Consultation Paper on Revision of Credit Rating Agencies Regulation Consultation Paper on Endorsement of Third Country Credit Rating Agencies CESR 2010 Annual Report on Credit Agencies Link to speech by ESMA Chairman, 16 May 2011 Link to ESMA Technical Advice on Fees for CRAs, 17 May 2011 ESMA Final Report on Application of Endorsement Regime, 18 May 2011 Link to ESMA Press Release re Japanese FSA co-operation, 6 June 2011 EP Resolution, 6 June 2011 ESMA Consultation Paper, 19 September 2011 and responses received ESMA list of registered and certified CRAs

Crisis Management – Recovery & Resolution

Crisis management in the

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Financial Sector Various consultation papers have been published by EU Commission ESMA published summary report on mapping contingency measures in January 2011 EU legislative proposals for banking resolution and recovery framework due September 2011 EC to publish guidelines in December 2011 for rescue and restructuring of financial institutions to ensure continuity when present rules expire. Target date for introduction of new rules for rescuing and restructuring of EU banks (speech by Joaquin Almunia), 1 January 2012.

Communication on a new EU framework for crisis management in the financial sector Consultation Paper on Crisis Management in the Banking Sector EU Press Release on Crisis Management ESMA Report on Mapping Contingency Measures Commission's Homepage on Crisis Management in Financial Sector Speech by Joaquin Almunia

Bank of International Settlements Progress Report, 6 July 2011

Deposit Guarantee Schemes

Revision of the Deposit Guarantee Schemes Directive

In July 2010, the Commission adopted a legislative proposal for revising the Deposit Guarantee Schemes Directive. The European Central Bank published its opinion in February 2011. EP economics committee approved revised compensation limits in May 2011. EP: plenary session for adoption of proposals on 12 October 2011. Proposals to be adopted by member states by end 2012.

Commission Homepage on Deposit Guarantee Schemes EU Commission's Proposals on Deposit Guarantee Schemes Summary of the Impact Assessment for Revision of the Deposit Guarantee Schemes Directive ECB Opinion, Feb 2011 FSA Deposit Guarantee Schemes Directive Summary Press Release re EP approval of revised limits, May 2011

Derivatives

OTC Derivatives reform

In September 2010 the Commission adopted a new regulation on OTC derivatives including rules on central counterparties (CCPs) and trade repositories. The European President published a compromise text proposal on 29 April 2011. EP Economics Committee approved draft on 24 May 2011. EP adopted Committee draft 5 July 2011. EP delayed its vote on the European Market Infrastructure Regulation (EMIR) until September 2011. The European President published a compromise text proposal on 15 September 2011 It is envisaged that the new rules on OTC derivatives, central counterparties

RegZone Article on OTC Derivative Reform Commission's Homepage on OTC Derivatives Reform ECB Opinion on Proposals for OTC Derivatives, Central Counterparties & Trade Depositaries, January 2011 EP Regulatory Report, 19 April 2011 EU Presidency Compromise Text Proposal, 29 April 2011 FSA EMIR Summary EP Consolidated Text, 5 July 2011 EU Presidency Compromise Text Proposal, 15 September 2011 EMIR proposal for regulation

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and trade repositories will come into force at end of 2012. EMIR proposal published 20

October

2011

Level 1 Directive to be voted on by EP 16-19 January 2012 ESMA to develop level 2 technical standards by September 2012

Measures on Short Selling/Credit Default Swaps

EU Commission proposed Regulation on short selling and credit default swaps, September 2010. EP held first reading on the Regulation, 14 March 2011; it is envisaged that this will apply from 1 July 2012. European finance ministers agreed position on short-selling and credit default swaps for negotiation with EP on 17 May 2011. EC Council published proposed Regulation on 17 May 2011, with date for coming into effect of 1 July 2011. EP endorsed report restricting right to purchase Credit Default Swaps to those owning related sovereign bonds. 4-7 July 2011. On 9 August 2011, ESMA published an updated table of measures adopted by authorities within EU on short-selling. ESMA released a statement on short-selling, 11 August 2011 EP press release on 15 November 2011 noted parliament voting into law a regulation to curb short selling and trading in CDS.

EU Commission Homepage on Short Selling and Credit Default Swaps European Central Bank Opinion, March 2011 European Council Press Release, 17 May 2011 Council of the EU Proposed Regulation, May 2011 EP Tabled Legislative Report, 6 June 2011 EP Consolidated Text adopted 5 July 2011 ESMA List of Measures Adopted re Short Selling, 9 August 2011 ESMA statement, 11 August 2011 EP press release, 15 November 2011

Financial Conglomerates Directive

Revision of the Financial Conglomerates Directive

EU Commission proposed to amend existing rules governing supervision of financial conglomerates in August 2010. Presidency compromise text for proposed revision of Financial Conglomerates Directive published June 2011. EP reading, 5 July 2011 Directive amending the Financial Conglomerates Directive published, 9 November 2011 Revision of Financial Conglomerates Directive to come into effect during 2012.

Commission's Homepage on Supplementary Supervision of Financial Conglomerates Consultation on Revision of the Financial Conglomerates Directive Proposed Directive Revising the Financial Conglomerates Directive FSA Financial Conglomerates Directive Summary Presidency Compromise Text, June 2011 EP reading, 5 July 2011 Directive amending Financial Conglomerates Directive

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Financial Sector Taxation

Legislative and Non Legislative initiatives on Financial Sector Taxation

In October 2010, EU Commission set out ideas financial sector taxation. EU Commission launched consultation in February 2011. Responses published and summarised on 24 May 2011. Economic and Social Committee opinion published 14 June 2011 EU Commission published proposal for a Directive on a Common Consolidated Corporate Tax Base on 16 March 2011. The Brussels Tax Forum discussed ways in which the financial services sector could make a ‘fairer contribution’ to taxation on 28 March 2011. EC produces proposal for a directive on a common system of financial transaction tax 28 September 2011 EP’s Economic and Monetary Affairs Committee to begins work on legislative proposal 9 January 2012

Commission's Homepage on Taxation of the Financial Sector Commission Consultation Paper, February 2011 Responses to Consultation, May 2011 Summary of Responses to Consultation, May 2011 Commission's Communication on Taxation of the Financial Sector EU Commission Proposal for Directive on Common Consolidated Corporate Tax Base EU Commissioner's Speech at Brussels Tax Forum Economic and Social Committee Opinion, 14 June 2011 EC proposal for FTT EP press release on Eurozone financial transaction tax

Innovative Financial Instruments

Initiatives on innovative financial instruments for the Multi-Annual Financial Framework

EU Commission published staff working paper in April 2010 ECOFIN due to publish communication on innovative financial instruments in by end 2011.

EU Commission Staff Working Paper 2010

Insurance Guarantee Schemes

Legislation on Insurance Guarantee Schemes

Consultation on Insurance Guarantee Schemes closed November 2010. Summary of responses published February 2011 European Economic and Social Committee opinion published 5 May 2011 European Economic and Social Committee opinion on White Paper published 27 July 2011 EU Commission confirmed no Europe-wide Scheme envisaged, July 2011 EU Commission legislative proposals now expected in autumn 2012

Commission's Homepage on Insurance Guarantee Schemes White Paper on Insurance Guarantee Schemes Summary of consultation responses Draft Impact Assessment accompanying White Paper on Insurance Guarantee Schemes EESC Insurance Guarantee Schemes Page with link to Opinion 5 May 2011 Economic and Social Committee Opinion, 27 July 2011 FSA Insurance Guarantee Schemes Directive Summary

Insurance Mediation Directive Revision (IMD2)

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Insurance Mediation Directive revision

Consultation on revision of the Insurance Mediation Directive closed 28 February 2011. Summary of responses published on 4 April 2011. IMD2 Commission proposals expected February 2012 Implementation of IMD2 anticipated 2013-2014

Commission's Homepage on Insurance Mediation Directive Consultation Document on revision of the Insurance Mediation Directive Summary of Responses to Commission Consultation, 4 April 2011 Current European Legislation on Insurance Mediation

Investor Compensation Scheme Directive

Revision of the Investor Compensation Schemes Directive (see also Deposit Guarantee Schemes above)

EP published draft report, 25 January 2011 ECON Committee approved report, 12 April 2011 EP adopted ICSD on 5 July 2011 Proposals are anticipated to come into effect by the end of 2012.

Commission's Homepage on Investor Compensation Schemes Proposed Directive Amending Investor Compensation Scheme Directive Summary of the Impact Assessment European Central Bank Opinion, Feb 2011 RegZone Page on Consumer Protection: FOS, Complaints handling, Compensation and Collective Action FSA ICS Directive Summary EP Director-General Briefing Notes June 2011

Market Abuse Directive

Revision of the Market Abuse Directive

EU Commission’s proposals on revision of Market Abuse Directive delayed to October 2011 MAD level 3 guidelines expected by end of 2011. European Parliament produced draft proposals for a Market Abuse Regulation (MAR) and a Directive on criminal sanctions for insider dealing and market manipulation (CSMAD) on 20 October 2011

Consultation Paper on revision of Market Abuse Directive EU 2011 Programme FSA Homepage on Market Abuse RegZone Article on Enforcement Fines from FSA Market Abuse Directive Simon Morris' Interview on Bloomberg on Recent Dawn Raids FSA Market Abuse Directive Summary RegZone article on MAD MAR proposal CSMAD proposal ESMA Q&A on the definition of inside information for MAD

MiFID

Review of the Markets in Financial Instruments Directive

Extensive 2010 consultation on MiFID review. EU Commission launched consultation

Commission's MiFID Homepage Commission's Consultation Paper on MiFID Review

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in December 2010 and set out views on 24 February 2011. In December 2010 the EP published the provisional text of a resolution passed by MEPs on regulation of trading in financial instruments. Rapporteur (to write report for ECON committee) appointed 10 May 2011. EMSA produced opinions on waivers from pre-trade transparency (MiFID requirement), 10 August 2011 EU Commission’s review of MiFID published 20 October 2011. EP released questionnaire on MiFID, responses required by 13 January 2012 The first ECON debate to discuss MiFID II draft legislation scheduled for 13 February 2012 The final draft of legislation expected to be agreed in late 2012/early 2013 with implementation anticipated in 2015

Responses to Consultation Paper The International Swaps and Derivatives Association response to Consultancy Paper EP resolution of 14 December 2010 on regulation of trading in financial instruments. FSA MiFID Summary ESMA opinions, 10 August 2011 EC MiFID proposals RegZone article on MiFID EP MiFID questionnaire

Occupational Retirement Pensions

Review of the Directive concerning Institutions for Occupational Retirement provisions (IORP)

EU Commission published report on key aspects of IORP in April 2009 and Green Paper in Jul 2010. Green Paper adopted by EP in February 2011. EIOPA launched consultation on IORP review in July 2011, deadline 15 August 2011. Response to call for advice published 7 November 2011. European Economic and Social Committee published opinion on proposed revision to EIOPA and ESMA powers, 23 July 2011 Commission proposals expected December 2012.

European Commission 2009 report on IORP European Commission Green Paper, July 2010 EP Resolution, Feb 2011 EIOPA Consultation Paper, 8 July 2011 EIOPA response to call for advice, 7 November 2011 CEA Key Messages re IORP review consultation Committee Opinion on EIOPA powers

Omnibus Directive

“Omnibus II” Directive

On 19 January 2011 the Commission proposed draft Directive revising the “Omnibus II” Directive to complete framework of financial supervision in Europe. EP approved new supervisory framework in September 2010. New European Supervisory Authorities established December 2010: ESMA, EIOPA, EBA and ESRB. Proposed “Omnibus II” Directive makes amendments to Level 1 of Solvency II.

Proposed Omnibus II Directive Original Omnibus Directive Regulation Establishing the European Insurance and Occupational Pensions Authority (EIOPA) Regulation Establishing the European Banking Authority (EBA) Regulation Establishing the European Supervisory and Markets Authority (ESMA)

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A Fourth Presidency Compromise Paper on the amendments was published 14 June 2011. EIOPA produces consultation paper on Own Risk and Solvency Assessment (ORSA) 9 November 2011 Omnibus II report scheduled for EP committee adoption, 22 November 2011 EP adoption of Omnibus II Directive scheduled for 17 January 2012.

Regulation on European Union macro-prudential oversight of the financial system and establishing a European Systemic Risk Board European Council Regulation conferring specific tasks upon the European Central Bank concerning the functioning of the European Systemic Risk Board 4

th Presidency Compromise Paper, June

2011 EIPOA ORSA consultation, 9 November 2011

PRIPS

Packaged Retail Investment Products

Consultation on Packaged Retail Investment Products November 2010 - January 2011. New rules on Packaged Retail Investment Products will fit in to EU Commission’s review of MiFID. EU Commission commented in March 2010 that scope of PRIPS may be narrowed to disclosure only. Legislative proposals for standardising pre-contractual information for retail investors expected Q3 2011 EC Directive to be produced in February 2012.

Commission's Homepage on Packaged Retail Investment Products Consultation Paper on Packaged Retail Investment Products Responses to Consultation Paper RegZone Article on Packaged Retail Investment Products

Prospectus, Listing and Transparency Rules

Prospectus Directive amendments

Amending Prospectus Directive came into force 31 December 2010. ESMA published responses to consultation, 29 July 2011 ESMA provided technical advice to EU Commission 4 October 2011. EU Commission will adopt delegated acts by end 2011. Amending directive to reduce burden on insurers expected April 2012. Member States have until 1 July 2012 to implement the new amendments.

Commission's Homepage on Prospectus Directive review Directive Amending the Prospectus Directive ESMA Call for Evidence ESMA List of Responses, 29 July 2011 RegZone Article on New Prospectus Rules FSA Prospectus Directive Summary ESMA technical advice on delegated acts

Revision of Directive on Transparency Obligations of listed companies

Throughout 2010 the Commission conducted a consultation on a review of the Directive on Transparency Obligations of listed companies. European Council Directive adoption 11 October 2010. Commission proposals for Directive

Commission's Homepage on Transparency Requirements for a Listed Company Consultation on Review and Harmonisation of Transparency Requirements for Listed Companies Report on the Application of

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amendments published 25 October 2011. Proposal for a Directive on harmonisation of transparency requirements published, 11 November 2011

Transparency Requirements FSA Transparency Directive Summary Commission proposals for Directive amendments Proposal for a Directive on harmonisation of transparency requirements

Third Country Prospectus Issuers

On 23 March 2011, ESMA published a framework on the way in which third country issuers can meet PD requirements. Prospectuses from non-EU countries drawn up in accordance with third country legislation can have a ‘wrap’ added, so that documents meet EU PD requirements.

ESMA Public Statement FSA Handbook Rule 4.2.1

Responsible Mortgage Lending and Borrowing

Regulation on Responsible Mortgage Lending and Borrowing

EU Commission consultation on ‘Responsible Lending and Borrowing in the EU’ in June 2009 followed by working paper in July 2010. EU Commission proposal for Directive on credit agreements relating to residential property, 31 March 2011. Staff working paper summarising Impact Assessment, 6 April 2011 Economic and Social Affairs Committee opinion published 14 July 2011 EP report on credit agreements relating to residential properties was scheduled to be adopted in committee, 24 October 2011.

Public Consultation on Responsible Mortgage Lending and Borrowing Responses to Consultation Commission's working paper of July 2010 Proposed Directive on Credit Agreements on Residential Property

Sanctions

Communication on sanctions in the financial services sector

EU Commission consultation on review of sanctions in the financial sector closed 19 February 2011. EU Commission is to decide on legislative proposals during 2011.

Commission's Homepage on Sanctions Commission's Consultation on Sanctions in the Financial Sector Commission's Press Release on Sanctions in Financial Sector December 2010 Summary of the Impact Assessment

Securities

Harmonisation of Securities Law

Second consultation on harmonisation of securities law closed 21 January 2011. Securities Law Directive was due July 2011, but delayed, probably to May 2012. Legislation to be transposed by Member States by the end of 2013.

EU Commission's Homepage on Harmonisation of Securities Law Responses to Consultation Paper Consultation Document on Legal Certainty of Securities Holding and Dispositions Geneva Securities Convention

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Hague Securities Convention ESMA Securities & Markets Stakeholder Group

Regulation on Central Securities Depositories (CSD’s)

EU Commission consultation on Central Securities Depositories closed 1 March 2011. Legislative proposals on Central Securities Depositories expected by end 2011.

Commission's Homepage on Central Securities Depositories Consultation on Central Securities Depositories EU 2011 Programme

SEPA

Regulation on SEPA (Single European Payments Area)

In December 2010 the EP proposed Regulation establishing technical requirements for credit transfers and direct debits in Euros. Second SEPA benchmarking study due to take place mid-2011. A second edition of the White Paper on remote payments planned for Q3 2011.

ECB report, 7 April 2011

Technical requirements for credit transfers and direct debits adopted in committee 7 July 2011, was due for adoption by EP in plenary session 26 September 2011

Commission's Homepage on Single European Payments Area Proposal for Regulation Establishing Technical Requirements for Credit Transfers and Direct Debits in Euros Summary of Impact Assessment First Implementation Report on SEPA Roadmap ECB opinion, 7 April 2011

Solvency II

Solvency II Directive

Solvency II Directive adopted in 2009. EU Commission consultation November 2010. Final advice to be provided by end July 2011 on equivalence of first wave third country supervisory regimes Introduction of calculation of new risk sensitive capital requirements plus level 2 technical measures planned for Q4 2011 Implementation measures on capital requirements for insurance undertakings to be agreed on by end 2011 Insurers must submit their Solvency II capital models for approval between “end March 2012 and mid-2013” Deadline for insurers to be subject to Solvency II rules has been postponed to 1 Jan 2014 See above “Omnibus II” Directive.

Commission's Homepage on Solvency II FSA's Solvency II Homepage Consultation on Level 2 Implementation of Solvency II Responses to Consultation Commission Legislative Proposals list Updated Timeline on Level 2 Implementation of Solvency II FSA Solvency II Project Summary European Timeline chart produced by FSA European Council Presidency Compromise text, June 2011

Supervision

European Systemic Risk Board (ESRB) and the three European Supervisory

Commission's Homepage on Financial Supervision

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Supervision package (European Systemic Risk Board and European Supervisory Authorities) – see also ‘Omnibus II’ Directive above.

Authorities (ESAs) came into being on 1 January 2011. Having launched the new supervisory authorities, EU Commission adopted legislative proposals to clarify new powers bestowed on them. See above ‘Omnibus II’ Directive. EU Commission proposals for amending directive on supplementary supervision of financial entities within financial conglomerates (amending Directives 98/78C, 20002/87 EC and 2006/48 EC) published 16 August 2010. Draft Report on amending directive by EP Committee 6 December 2010.

Statement by Commissioner Barnier EBA Official Website ESMA Official Website EIOPA Official Website RegZone Article on the new European System of Financial Supervision Commission amending directive proposal Draft EP Committee Report European Central Bank Opinion on Draft Directive Amendments for Supplementary Supervision of Financial Entities in a Financial Conglomerate Speech by Jean-Claude Trichet, President of the ECB, 17 February 2011

UCITS

Amendments to UCITS Directive, UCITS IV

FSA and HM Treasury consultation on implementation of UCITS IV Directive closed 21 March 2011. ESMA launched consultation on UCITS exchange-traded funds and Structured UCITS, responses were due by 22 September 2011 Amendments to UCITS Directive due December 2011. Legislative proposal on UCITS V due to be adopted in early 2012, with political agreement to be sought throughout 2012.

FSA and HM Treasury Consultation Paper on the implementation of UCITS IV Recast UCITS Directive CESR's technical advice on level 2 measures relating to UCITS CESR's level 3 guidelines RegZone Article on new UCITS IV regime Commission's Implementing Measures (2 Regulations & 2 Directives) ESMA Consultation Paper on UCITS exchange-traded funds and structured UCITS FSA UCITS Directive Summary

Last updated 11 January 2012

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