Read the latest information available for you and your clients.
Our current Brexit position on 30 October 2019
Under the latest extension to the Article 50 timetable the UK will continue to be a member of the EU until 31 January 2020. In the meantime a UK General Election will be held on Thursday 12 December with the aim of breaking the current political deadlock over the UK’s exit from the EU.
As a consequence the timing and terms of the UK’s withdrawal from the EU are unlikely to become clear until a new government is in place.
As part of our Brexit planning we have considered a number of different Brexit scenarios, including the possibility of the UK leaving the EU without an agreed deal, and put in place agreements to mitigate any potential disruption for our customers, clients and operations.
We will continue to follow the political process and review the arrangements we have put in place in the light of any major developments. As a global investment manager we have extensive experience of adapting to regulatory change and working across borders.
Our priority is to ensure we are in the best possible position to provide our customers and clients with continuity of service, regardless of the circumstances in which the UK may eventually leave the EU.
The information on this site is for qualified financial advisers and must not be relied on by anyone else. If you're not an adviser, please go to our customer website for more information about our products and services.
The FCA introduced a Temporary Permissions Regime (TPR) as part of no-deal Brexit planning. This lets investment managers with funds domiciled in the European Economic Area (EEA) continue to operate in the UK in the event of a no deal Brexit. Typically these funds will have the prefix LUX (Luxembourg) or IE (Ireland) ISIN prefixes on our platforms.
To qualify for the TPR, the investment manager must register its fund(s) with the FCA on or before 30 October 2019. Registration must be made at fund level, not in aggregate as a fund manager.
If an investment manager fails to register a fund(s), or decides it wants to stop passporting fund(s) after Brexit, the FCA will automatically assume the fund(s) falls under the Financial Services Contracts Regime (FSCR). UK investors will still be able to stay invested in a fund (the fund manager may withdraw access sooner), and will be allowed to sell-out either incrementally or in totality. They will not, however, be able to buy into the fund and it will be closed to new investments.
The FCA has confirmed that the TPR Register will only be available for public viewing after 31st October 2019, assuming the UK leaves the EEA on 31st October 2019. We also believe that the Register will only include the fund name without any unique identifier such as a CitiCode or ISIN.
We’ve written to all fund groups with EEA-domicile funds available on our platforms, asking for details about which funds have been registered under TRP and which default to FSCR. Our aim is to make sure our platforms offers access to those funds registered with TPR on 1st November 2019, but cannot categorically guarantee this given the TPR Register will not be published until 1st November 2019
We’ll make every effort to provide you with the necessary reassurances, but you should contact the fund group if you have any specific concerns and to check how this might impact impact your clients.