Author Archives: admin
‘Reasonable Steps’ in the Regulated World
Lucy McClements There is no doubt that being a Senior Manager Function holder (SMF) in today’s regulatory environment comes with increased risks. Regulatory expectations have been enhanced thus creating additional pressure on Boards and individuals to evidence their competence on …
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Tagged in: Approval, Expert, FCA, FSExpert, McClements, senior managers regime, SMCR, SMF, Witness
Hardly Diverging
Almost at the very end of the fourth month after our final separation from EU legislation, the FCA published its first proposals for going it alone. CP21/9 sets out its grandly entitled Changes to MiFID’s Conduct and Organisational Requirements. But …
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Tagged in: Best Execution, BREXIT, competition, Divergence, EU, FCA, MiFID, MiFID II, Research
Treating EU customers fairly
While we have been known to suggest that the EU does not always act as it should, in some areas, whether right or wrong, it has at least the merit of consistency. One such area is its approach to determining …
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