What FinReg Has in Store for Q1 2020

January 06, 2020
  • Global Regulatory Team

We highlight what to expect this quarter and recap Q4’s key regulatory developments.

What could change the game in Q1:

  • Yet again, we’re approaching another Brexit deadline. If both sides can agree to terms prior to January 31, the separation will happen then. Otherwise, the end of January will be the final cutoff for a deal. Most asset managers have had contingency plans in place for several months now and have notified regulators of their plans.   
  • The industry has until next week to comment on October’s PRIIPs consultation paper. Soon after, we can expect a review of PRIIPs, including some consumer testing of the revised scenarios and cost disclosures, and a submission of final revision proposals from the European Supervisory Authorities to the European Commission.
  • The fifth EU anti-money laundering directive (AMLD 5) takes full effect later this week as member states were given until January 10 to put enabling legislation in place. Beneficial owners will have to register in each country’s registry starting Friday.

What happened in Q4: 

  • In December, the US SEC approved several new active ETF structures that are semi-transparent, proxy-based, and opened the door for new product types.
  • On October 31, another Brexit day came and went without any separation between the EU and the UK. Elections in December kept Prime Minister Boris Johnson at the head and boosted his Conservative majority as many in the Labour party lost their seats.
  • The UK’s SM&CR took effect for asset managers as of December 9. The Senior Managers and Certification Regime holds firm leaders to a high professional standard and increases accountability on individuals and has extraterritorial applicability.

Top On The Regs Posts of Q4:

  • Top Down, Bottom Up: The Topsy Turvy World of Fund Liquidity | Read More
  • A Tip of the Hat to the Top Regulations of the Decade | Read More
  • Regulation Further Propels Asset Managers Towards Digital Transformation | Read More

Brown Brothers Harriman & Co. (“BBH”) may be used as a generic term to reference the company as a whole and/or its various subsidiaries generally. This material and any products or services may be issued or provided in multiple jurisdictions by duly authorized and regulated subsidiaries.This material is for general information and reference purposes only and does not constitute legal, tax or investment advice and is not intended as an offer to sell, or a solicitation to buy securities, services or investment products. Any reference to tax matters is not intended to be used, and may not be used, for purposes of avoiding penalties under the U.S. Internal Revenue Code, or other applicable tax regimes, or for promotion, marketing or recommendation to third parties. All information has been obtained from sources believed to be reliable, but accuracy is not guaranteed, and reliance should not be placed on the information presented. This material may not be reproduced, copied or transmitted, or any of the content disclosed to third parties, without the permission of BBH. All trademarks and service marks included are the property of BBH or their respective owners.© Brown Brothers Harriman & Co. 2021. All rights reserved.

This browser is not fully supported by our public website and may not display or function as expected for this reason. Please note, the Infuse Portal and BBH client applications fully support the IE 11 browser.

Important Information for Non-U.S. Residents

You are required to read the following important information, which, in conjunction with the Terms and Conditions, governs your use of this website. Your use of this website and its contents constitute your acceptance of this information and those Terms and Conditions. If you do not agree with this information and the Terms and Conditions, you should immediately cease use of this website. The contents of this website have not been prepared for the benefit of investors outside of the United States. This website is not intended as a solicitation of the purchase or sale of any security or other financial instrument or any investment management services for any investor who resides in a jurisdiction other than the United States1. As a general matter, Brown Brothers Harriman & Co. and its subsidiaries (“BBH”) is not licensed or registered to solicit prospective investors and offer investment advisory services in jurisdictions outside of the United States. The information on this website is not intended to be distributed to, directed at or used by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. Persons in respect of whom such prohibitions apply must not access the website.  Under certain circumstances, BBH may provide services to investors located outside of the United States in accordance with applicable law. The conditions under which such services may be provided will be analyzed on a case-by-case basis by BBH. BBH will only accept investors from such jurisdictions or countries where it has made a determination that such an arrangement or relationship is permissible under the laws of that jurisdiction or country. The existence of this website is not intended to be a substitute for the type of analysis described above and is not intended as a solicitation of or recommendation to any prospective investor, including those located outside of the United States. Certain BBH products or services may not be available in certain jurisdictions. By choosing to access this website from any location other than the United States, you accept full responsibility for compliance with all local laws. The website contains content that has been obtained from sources that BBH believes to be reliable as of the date presented; however, BBH cannot guarantee the accuracy of such content, assure its completeness, or warrant that such information will not be changed. The content contained herein is current as of the date of issuance and is subject to change without notice. The website’s content does not constitute investment advice and should not be used as the basis for any investment decision. There is no guarantee that any investment objectives, expectations, targets described in this website or the  performance or profitability of any investment will be achieved. You understand that investing in securities and other financial instruments involves risks that may affect the value of the securities and may result in losses, including the potential loss of the principal invested, and you assume and are able to bear all such risks.  In no event shall BBH or any other affiliated party be liable for any direct, incidental, special, consequential, indirect, lost profits, loss of business or data, or punitive damages arising out of your use of this website. By clicking accept, you confirm that you accept  to the above Important Information along with Terms and Conditions.

1BBH sponsors UCITS Funds registered in Luxembourg, in certain jurisdictions. For information on those funds, please see bbhluxembourgfunds.com

captcha image

Type in the word seen on the picture

I am a current investor in another jurisdiction