September 19, 2019

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FCA and PRA Publish Updates to the Temporary Permissions Regime

On March 25, the UK Financial Conduct Authority (FCA) updated its webpage on the temporary permissions regime (TPR) to announce that it intends to extend the notification window for European Economic Area (EEA) firms and fund managers wishing to enter the TPR to the end of April 11. On March 26, the UK Prudential Regulation Authority (PRA) also updated its webpage on the TPR to make an equivalent announcement. (For more information on the TPR, please see the Corporate & Financial Weekly Digest edition of January 11, 2019.)

The FCA’s and the PRA’s decisions follow the European Council’s decision to agree to a short extension to the Article 50 period to April 12 if the UK government’s Withdrawal Agreement is not approved by the House of Commons (and May 22, if it is).

The FCA also announced the publication of supplementary directions to provide guidance on how a firm can withdraw its notification. Firms that withdraw their notification in writing to the FCA before exit day will not enter the TPR. The PRA published an equivalent supplementary direction on withdrawals of notifications before exit day on March 22.

The updated FCA webpage is available here.

The updated PRA webpage is available here.

©2019 Katten Muchin Rosenman LLP

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John Ahern, Financial Attorney, London, Katten Law Firm
Partner

John Ahern, partner at Katten Muchin Rosenman UK LLP and head of the London Financial Services group, focuses his practice on banking, financial services, UK and European financial markets, and related regulations. His background in private practice and as in-house counsel at a global investment bank provides him with perspective on the unique regulatory issues facing the wholesale and private banking sectors. John advises multilateral trading facilities, broker-dealers and banks on trading, clearing and settlement as well as custody of securities—both physical and...

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Carolyn H. Jackson, International Attorney, Katten Muchin law firm
Partner

Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws and regulations. 

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Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring...

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Neil Robson, private equity fund managers counselor, Katten Law Firm, London
Partner

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...

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