PIMFA Weekly News Bulletin - 25 November 2024

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Featured: MSCI PIMFA Index Series New Asset Allocations, Upcoming Working Groups and Forums

25 November 2024

MSCI PIMFA Index Series: New Asset Allocations Effective 26 November 2024

The PIMFA Indices Committee met recently and agreed changes to the portfolio weights of the MSCI PIMFA Index Series’.

These changes will become effective Tuesday 26 November 2024.

• To view the decisions taken for the MSCI PIMFA Private Investor Index Series, click here.

• To view the decisions taken for the MSCI PIMFA Equity Risk Index Series, click here

Note: the respective Current Asset Allocations pages will be updated after 18:00 on Monday 25 November 2024.

PIMFA Regulatory Forum: Tuesday 26 November 2024

The next Regulatory Forum will take place online on Tuesday 26 November 2024 from 15:0016:00.

The agenda includes:

• Mansion House Overview:

o The Financial Conduct Authority (FCA) Call for Input: Modernising the Redress System

o HM Treasury (HMT) Call for Evidence: Financial Services Growth & Competitiveness Strategy

• FCA Enforcement Proposals Update

• FCA Dear CEO letter for SIPP Operators

• HMT Consultation on Inheritance Tax on Pensions

• HMT Consultation on UK Green Taxonomy

• HMT Consultation Response on Future Regulatory Regime for ESG Ratings Providers

• The Financial Reporting Council (FRC) Consultation on Updates to UK Stewardship Code

PIMFA Forums are open to representatives from all PIMFA Member and Associate firms. If you or any of your colleagues would like to attend the Regulatory Forum and are not currently on our distribution list, please email Heidi Bryant

PIMFA Cyber Security and Operational Resilience meeting: 'Cyber attack scenarios and their impact on maintaining Operational Resilience'

Join us on 28 November from 15:00 - 17:00 at JM Finn, 25 Copthall Ave, London, for a meeting of the Cyber Security and Operational Resilience Working Groups.

We will be exploring the impact of cyber attacks on wealth management firms, with insights from Ken Munro of PenTest Partners and Inspector Charlie Morrison from the City of London Police. Attendees will have the opportunity to discuss attack scenarios, share knowledge, and consider response and recovery strategies.

If you are from a PIMFA member firm and wish to attend, please email Maria Fritzsche

The FCA has published a discussion paper on improvements to Transaction Reporting. The aim is to enhance data quality and reduce reporting burdens, aligning with international standards. This initiative, based on the UK Markets in Financial Instruments Directive (MiFID), aims to improve market cleanliness, transparency, and resilience.

Join our Transaction Reporting Working Group Meeting to Explore FCA DP24/2 'Improving the UK Transaction Reporting Regime'

With a deadline of 14 February 2025, the FCA will consider feedback and consult on proposed changes before finalising new rules. Key areas of focus include clarifying reportable instruments, addressing operational challenges, and improving data quality through new identifiers and fields. An opt-in register for small firms is also being considered.

We will discuss the paper at our next Transaction Reporting Working Group meeting, which will be held via Teams, on Thursday 12 December between 11:00 - 13:00. If you are from a PIMFA member firm and would like to attend, please email Maria Fritzsche or Kevin Sloane

Next PIMFA CASS Working Group Meeting Tuesday 10 December 10:00 - 12:00 via Teams

The group will be joined by Rob Johnston, Senior Manager at PwC, who will present on the findings of their recent CASS audits, followed by a Q&A session.

If you are from a PIMFA member firm and wish to attend the CASS Working Group, or you have any CASS-related questions to raise at the meeting, please email Maria Fritzsche or Kevin Sloane.

FCA PS24/16: Operational Resilience: Critical Third Parties to the UK Financial Sector

The Bank of England, the FCA and the PRA have recently published a joint policy statement on operational resilience for critical third parties (CTP) to the UK financial sector. The policy statement outlines the final rules and guidelines for ensuring these entities can maintain essential services during disruptions. It requires CTPs to comply with specific rules on governance, risk management, technology and cyber resilience, incident management, and supply chain risk management.

The rules take effect from 1 January 2025, with transitional periods for certain requirements. HMT will be making the final decisions on which third parties are considered a CTP. The financial regulators agreed on how they will coordinate their work on CTP functions, which includes a joint CTP Consultation and Coordination Forum. For more details, please see the Memorandum of Understanding.

The full policy statement can be found here.

FCA Feedback: Advice Guidance Boundary Review statement

The FCA has published a feedback statement on the Advice Guidance Boundary Review setting out their updated approach to help people access financial and investment support.

The statement notes that the FCA:

• Want firms to consider how they can better support their customers

• Will engage directly with small advice firms in 2025 to gauge the willingness and capacity of these firms to offer a simplified advice service

• The Government and the FCA will keep these options under review as the proposals for a targeted support regime develop.

Noting the wider context, the FCA intends a new retail disclosure regime to be in place in H1 2025, subject to the consultation process and will consult on proposed rules for the Consumer Composite Investments regime in 2024.

Interested firms can contact the FCA and test propositions in digital sandboxes.

Read the full statement here

The FCA, ICO and TPR Joint statement for Retail Investment Firms and Pension Providers

The FCA, Information Commissioner's Office (ICO), and The Pensions Regulator (TPR) have published a joint statement.

The aim is to provide greater clarity for firms to support their customers decision-making through their communications (in line with the FCA Consumer Duty and TPR’s Code of Practice and Guidance).

The regulators joint position is set out in the statement:

• Firms and pension scheme trustees or managers can provide regulatory communication messages to customers even if they don’t have direct marketing permissions from them, (provided these are not direct marketing) to give neutral, factual information that supports them to make informed decisions about retail investments and pensions options, including at retirement.

• As the context and content of the message must be considered, firms should refer to the ICO’s direct marketing and regulatory communications guidance.

• UK data protection laws do not stop firms from sending these regulatory communications. However, firms must ensure that they comply with data protection requirements.

Read the full statement here

Financial Services Compensation Scheme Report: Outlook November 2024

The Financial Services Compensation Scheme has published the latest edition of its Outlook report, setting out an update for the 2024/25 levy as well as the 2025/26 levy forecast.

The 2024/25 levy remains unchanged at £265m and the initial forecast for the 2025/26 levy is £394m.

Access the report here

Financial Services Skills Commission Industry Survey 2024

The Financial Services Skills Commission’s (FSSC) annual industry survey offers insight into skills challenges across the industry and highlights what future skills are required for the sector to remain competitive.

Aimed at HR and learning professionals, or senior decision-makers, the survey consists of around 20 questions and will take 10-15 minutes to complete, and closes on 2 December

2024.

Please respond to the survey here.

FSSC members have received a separate survey link and do not need to respond to this survey unless it is to represent a specific regional office. You’ll be asked questions about:

• Skills supply and demand

• The impact of Generative AI and Net Zero

• Skills forecasting and reskilling

All data submitted will be treated as confidential and is covered by their data policy statement. Findings will only be presented in aggregate form, and no individual responses will be shared with other firms.

For any questions, please contact the Commission’s Policy and Research Manager Katharina Ehrhart. The Commission will also offer an optional drop-in session for all survey respondents on 19 November from 15:00 - 16:00. Thank you for your participation and support.

UK Green Taxonomy Consultation

On 14 November 2024 HM Treasury issued a consultation on a UK Green Taxonomy, with the purpose of supporting investment into activities aligned with sustainability goals, and mitigating greenwashing.

The consultation is seeking views on whether a UK Green Taxonomy would be additional and complementary to existing sustainable finance policies, including in supporting market participants to make sustainable investment decisions, and the specific market and regulatory use cases which facilitate this.

In addition to developing a clear understanding of the use cases, the government is also seeking feedback on how to maximise the usability of a UK Taxonomy, should respondents support taking one forward. This includes considering key design features that will impact the overall usability of a UK Taxonomy.

PIMFA’s Sustainable Finance Working group will be meeting to discuss the consultation and help shape PIMFA’s response. If you would like to get involved, please contact Maja Erceg.

Information Commissioner's Office Information Sharing Pilot - Evaluation

Report

A report on the ICO Sandbox has been published in partnership with our colleagues at UK Finance.

• Participating Banks met the relevant thresholds and implemented appropriate safeguards to lawfully share data for the prevention of financial crime under UK GDPR and DPA 2018.

• The pilot successfully enabled 12 weeks of live data sharing following the development of a UK GDPR compliant legal framework.

• The pilot has demonstrated that legally and operationally it is possible to share financial crime exit data directly between financial institutions for the purposes of economic crime prevention and to inform the risk-based approach.

Access the report here.

HM Government: Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024

The Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 was laid in Parliament (14 November 2024), introducing various changes to sanctions legislation with the aim of improving implementation of financial sanctions and to clarify financial sanctions legislation where there is existing uncertainty (e.g. clarification that a designated person includes a person who is owned or controlled by the firm).

These changes encompass:

• an expansion of the definition of relevant firms subject to financial sanctions reporting obligations to cover additional sectors (adding four types of firm)

• a requirement to report suspected breaches of sanctions regulations (as opposed to suspected offences)

• a requirement for all UK persons that hold funds or economic resources owned, held, or controlled by a designated person, to provide an annual report to OFSI with the details of these assets

OFSI has updated guidance documents to reflect these changes which (with the exception of

the extension of reporting obligations on other sectors) will come into force on 5 December 2024.

A blog regarding the changes has also been published – read it here.

PRESS RELEASES

PIMFA delighted to welcome two new members to its Board of Directors

Budget changes will be hard felt by retail investors and the Government must now prioritise stability to build investor confidence

PIMFA welcomes 600 professionals at launch of customer vulnerability guide

Citywire Wealth Manager: Quilter Cheviot and Evelyn heavyweights join PIMFA board

IFA Magazine: PIMFA comments on FCA & FOS Announcement on CMC charges

Professional Adviser: Vulnerability taboos deterring clients from seeking additional adviser support

PRESS COVERAGE

PIMFA LEARNING AND EVENTS

NEW FOR 28 JANUARY 2025

Live Online

£850 - £1050

PIMFA Learning: The SMF Regulatory Briefing Programme 2025 – All You Need to Know About Everything That Matters Most

PIMFA’s new 12-month Senior Managers Function (SMF) Regulatory Briefing Programme supports SMF holders in learning everything they need to know about the issues that matter most to them. It also prepares prospective SMF holders for the highest level of leadership.

The programme consists of a series of monthly live, online one-hour sessions on critical compliance, risk and financial crime challenges, enabling SMFs to:

• Keep up to date with the latest regulatory trends and initiatives

26 February 2025

Live Event and Online| 10:00 - 17:00

£250 - £600

PIMFA Financial Crime Conference 2025

Join us at the offices of Shoosmiths in London, for our our annual one-day financial crime conference exclusively for compliance experts, financial crime specialists, and financial advisers.

The world is changing quickly and the pace of criminal activity and threat actors targeting our sector has not slowed. This event will be dedicated towards giving attendees the information they need to protect themselves and their clients to stay ahead of those with malicious and harmful intent.

• Demonstrate their commitment to regulatory proficiency

• Access the training at a convenient time, through our on-demand learning platform

• Document CPD activity as required

• Highlights and key outcomes

By enrolling on this Programme SMFs will be able to:

• Evidence to the FCA their in-role competency and capability required under SMCR.

• Rapidly assess the firm’s compliance exposure and vulnerabilities.

• Get ahead and make sense of a broad, complex, and ever-evolving regulatory and compliance landscape.

• Set priorities to develop a proactive regulatory change management programme.

• Lead your firm on how best to mitigate risks, create a firm-wide compliance culture, make sound decisions, and build resilience across the business.

• Improve their strategic thinking and ability to respond to regulatory change effectively.

• Explore with peers the latest research and best practices for managing risk to safeguard enterprise value.

The day will feature headline updates from the industry including:

• Keynote speech from the FCA on regulatory priorities for 2025 in the FinCrime space

• Keynote address from the Homeland Security Group at the Home Office, on the latest updates to the ongoing Economic Crime Plan 2

• Special session from the National Economic Crime Command (NECC) at the National Crime Agency (NCA) on SARS

• Legal update on what firms need to know within fraud and regulatory for 2025, featuring hosts Shoosmiths LLP

Book your early-bird tickets here.

Click here for more information and booking.

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