Russell Facer

Compliance tip: Do you need to opt out of Mifid II?

There are many reasons why a firm might wish to amend its status from Exempt CAD to Article 3. Exempt CAD firms have usually opted into Mifid in order to passport their investment services into another EU member state, or to enable them to transmit orders in unregulated collective investment schemes to non-Mifid firms. Article […]

Compliance tip: Reducing Gabriel completion stress

The deadline is looming for many firms’ Gabriel reporting. Parts of the return are easier to fill in – training and competence, complaints, PI policy details, for example. But the accounting and capital adequacy sections need more preparation, as you will generally need to delve into management information or consult your accountant. A lot of […]

Compliance tip: Key changes to comply with Mifid II

The Insurance Distribution Directive, General Data Protection Regulation and Mifid II all impact how firms interact with clients, leading to necessary changes to client agreements. Here we consider the main alterations that will need to have been made to comply with Mifid II. It has always been necessary to describe the service to be received […]

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Mifid II checklist: Are you ready?

The implementation date for Mifid II (3 January) is rapidly approaching, with seasonal celebrations reducing preparation time further. Now is the time to conduct a self-assessment to establish your firm’s state of readiness. Mifid II affects investment advice and discretionary management firms differently, so your actions will be tailored to your firm type. In addition, advice […]

Compliance tip: An important reminder about PII

From 23 February, the Insurance Distribution Directive will set new minimum levels of professional indemnity insurance for firms involved in the distribution of insurance products. This affects all firms advising on, arranging or managing non-investment insurance contracts (pure protection contracts and life policies such as long-term insurance contracts and annuities), insurance-based investment products and general […]

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Compliance tip: Mifid II transaction reporting and legal entity identifiers

Transaction reporting Transaction reporting is the reporting of information about trades in reportable financial instruments, such as shares, ETFs, VCTs, investment trusts and structured products. Reporting covers purchases, sales and modifications of reportable instruments. Mifid II proposes important changes to these obligations which will potentially affect all investment firms. Some exemptions will apply. For instance, […]

Compliance tip: How to deal with clients who move abroad

We all have clients we have dealt with for many years; those who trust us and value the advice they receive. But what happens when these clients decide to move abroad and want you to continue advising them on their financial arrangements? This is an area that is not straight forward. There are a number […]

Compliance tip: Commission disclosure for pure protection contracts

We have seen confusion around commission disclosure on pure protection contracts (e.g. term assurance), partially due to interpretation of existing rules under the Insurance Conduct of Business Sourcebook. The new Insurance Distribution Directive introduces updated disclosure requirements from February 2018, which should hopefully simplify matters. Currently, commission on pure protection contracts only needs to be […]