Trends in market abuse
Market conduct poses risks to regulated firms irrespective of the markets they are in or the clients they serve. The nature of market abuse varies which we show in the Market Abuse Themes chart below. The FCA is of the…
Katharine Leaman
CASS: 6 things the FCA expects of you
FCA works on a risk-based approach and as such they group firms according to the level of risk the firm poses to the FCA objectives. For CASS (the FCA’s Clients Assets Sourcebook), the FCA determines this according to how much…
5 things to-do before the year end
1. Brexit Readiness EEA Incoming Firms FCA has said that it intends to allow substituted compliance with the equivalent obligation in your firm’s home state. This means that you do not have to do a massive rewrite and mapping of…
Why is FCA not receiving more non equity related STORs?
For several years now the FCA has been repeating its concern that the reporting of STORs (Suspicious Transaction Order Reports) is dominated by suspicious transactions in equities. More specifically what the FCA has referred to as the “poster child” of…
Finding breaches is not all bad news
Rules breaches can have negative connotations after all non-compliance is never good. It can depend of course on what the breach is, whether its material, affects many clients or appears systemic. A breach that you identify yourself, in-house, perhaps through…
Brexit and MiFID II Transaction Reporting
FCA’s Market Watch 64 is a timely reminder that the count down to the end of the Brexit Transition on 31 December 2020 is underway. What’s Changing? Back in June 2016 FCA said that EU Regulation would continue to apply…
Reducing your Compliance spend
As your firm starts doing new things and you find you have different rules and regulations to comply with where do you start? For many it begins with a Google search. The success of your Googling can come down to…
Risks of Remote Working
Since the outset of the Covid-19 outbreak in the UK PRA and FCA have been asking firms about their risk management and specifically looking to understand if firms are identifying any new or evolving risks. FCA especially has been concerned…
What’s going in your SMCR Breach Report?
Form H is the Notification of Disciplinary Action relating to conduct rules staff (other than SMF managers) in SMCR firms. Also known as REP008 in GABRIEL. Your breach report must cover breaches from 1 September to 31 August and must…
Matched Principal Exemption
Last week’s blog about the recent FCA CASS Dear CEO letter has prompted many questions, and particularly about the matched principal exemption. This is a brief note to address those common questions about the matched principal exemption. What is the…