Posts by Ian
“Unfair, Unclear and Misleading”
August 2026 The Financial Conduct Authority (FCA) has censured Equity for Growth (Securities) Limited (EFG) for approving minibond financial promotions that were “unfair, unclear, and misleading”. The FCA would have imposed a penalty of £386,467 had EFG not already been the subject of a winding up order. On the face of it, this case reflects…
Read MoreHM Treasury Consultation: The Appointed Representative Regime
HMT has issued a consultation on the Appointed Representative (“AR”) regime, which is open for eight weeks until 9th April 2026, seeking representations from any interested parties and stakeholders. The consultation follows on from its policy statement issued on 11th August 2025, outlining proposals to safeguard the future of the UK’s Appointed Representatives regime (see…
Read MoreCP25/36 Client Categorisation and Conflicts of Interest
The FCA recently published Consultation Paper 25/36 “Client categorisation and conflicts of interest” following on from its July 2025 announcement that it planned to review its “client categorisation rules to unlock greater opportunities for wealthy investors, strengthen capital markets and drive economic growth”. It is also a response to its supervisory work, firms’ feedback on…
Read MoreThe Latest FCA Appointed Representative Data
The FCA updates its Appointed Representative (AR) data every six months based on Principals’ submissions including: “Add, Change and Terminate” AR data helps us understand the main reason for appointing the AR, the nature of the AR’s business and activities, and expected revenue from regulated and unregulated activities”. “REP025 data is submitted annually and helps…
Read MoreFCA Authorisation Metrics Q2 2025/26
The latest “FCA Authorisations operating service metrics 2025/26 Q2” have just been published and read somewhat like a Soviet era election result with, “99.5% of applications across all metric areas were determined within the statutory deadline” and “Our performance shows 13 metrics are green, 1 is amber and none are red.” The amber metric (cancellation…
Read MoreProgressing Fund Tokenisation
Introduction In a bid to help the development and adoption of tokenised assets, the Financial Conduct Authority (“FCA”) has published consultation paper (CP25-28) titled “Progressing Fund Tokenisation.” The consultation applies to: UCITS management companies UK fund managers managing authorised funds Depositaries of authorised funds However, it will be of interest to the wider investment community…
Read MoreHM Treasury Policy Statement: The Appointed Representative Regime
His Majesty’s Treasury (HM Treasury) has issued an Appointed Representative (AR) Regime Policy Statement in response to its December 2021 Call for Evidence on the regulatory approach to ARs. The underlying drivers behind the Call for Evidence being the recent scandal involving the AR regime and the egregiously high levels of consumer complaints involving ARs.…
Read MoreThe FCA Reports on its “Strategy 2022 to 2025” Outcomes
In April 2022 the FCA launched a three-year strategy, called Strategy 2022 to 2025, to improve consumer outcomes across the range of the FCA’s growing remit. The strategy had several key priorities including preventing serious harm, setting higher standards, and promoting competition. For the first time the FCA also promised to hold itself accountable against…
Read MoreThe House of Lords Financial Services Regulation Committee Report Raises Concerns for UK Regulators
The Financial Services Regulation Committee (FSRC), a House of Lords Select Committee, has recently published a report for UK regulators titled ‘Growing pains: clarity and culture change required.’ In this article, we will explore some of the themes in the report including the ever-increasing compliance burden, compliance costs, Financial Conduct Authority (FCA) Authorisation process and…
Read MoreThe FCA Review of Smaller Asset Management Firms and Alternatives
On 8th May 2025, the FCA published its findings resulting from its review of smaller asset management firms. The review, part of the FCA’s 2022 Alternatives supervision strategy, sought to identify smaller firm business models posing increased risks of harm to consumers. Although, the FCA is clear that some of the findings may also apply to…
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