The UK has put in place legislation, slated to come into effect at the end of the implementation period, which means it may no longer be possible for EEA firms like Standard Life International to rely on the overseas persons exclusion.
Our original plans reflected a reliance on this exclusion so we have explored alternative options. We have concluded that Standard Life International will enter the Temporary Permissions Regime (TPR) which would give Standard Life International a deemed UK authorisation for as long as it is in the regime – please see details of the TPR via the Bank of England link below.
We are currently finalising the application for Standard Life International to enter the TPR and will submit this before the end of the year - unless of course there is reason not to do so, such as a Brexit trade deal covering Financial Services.
Once the PRA has received the application, Standard Life International will be deemed authorised in the UK and can continue with its current business model while working through the UK authorisation process. Therefore the current operating model will continue in effect in 2021.
We previously contacted International Bond customers to warn that FSCS protection may be lost when the UK left the EU. As we will be entering the TPR, our understanding is that this protection will continue for new and existing customers whilst we are in the regime and for so long as Standard Life International is deemed a "relevant person" under FSCS rules. We will continue to keep you updated on this point, including if there are any changes to our understanding of the rules.