Read the latest information available for you and your clients.
Our current Brexit position as at 3 February 2020
On Friday 31 January the UK ceased to be a member of the EU and entered a transition period during which EU law and regulation will continue to apply during negotiations on a Free Trade Agreement (FTA).
Official talks are expected to begin on 3 March with the aim of implementing a FTA before the end of the transition period on 31 December 2020; a deadline widely regarded as challenging due to the complexity and potential scope of the negotiations.
This is likely to lead to continuing uncertainty until there is greater clarity on the final terms of the agreement and the extent to which it will cover existing trade in goods and services, including financial services.
As part of our Brexit planning we have considered a range of scenarios, including the possibility of a FTA not being in place by the end of the transition period, and put in place arrangements to mitigate any potential disruption for our customers, clients and operations.
We will continue to follow developments closely and regularly review the arrangements we have in place, including those for a ‘cliff edge’ scenario. 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 scope and terms of any FTA which takes effect between the UK and the EU when the transition period comes to an end.
Please read our Brexit Q&A for more information.
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 withdrawal agreement is now in place and we’ve entered an ‘implementation period’ until 31st December 2020. Existing EU law will continue to apply, including existing pass-porting rights. As a result, the Temporary Permissions Regime will now take effect from the 31st December 2020. The window for notification is currently closed although the FCA has confirmed it will open again later in the year.You can read the latest FCA update from 31st January 2020.
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.