WMA Bulletin 12th January 2017 Dear WMA member WMA Bulletin is a fortnightly snapshot delivering the latest news and current affairs from within the wealth management industry and WMA.
What's going on in our industry? Automatic Exchange of Information (AEOI) User Guide HMRC has recently published an updated user guide in respect of Automatic Exchange of Information reporting covering FATCA, Crown Dependencies & Overseas Territories and the Common Reporting Standard. The user guide can be accessed here. Any queries on the submission of an AEOI return can be addressed to enquiries.aeoi@hmrc.gsi.gov.uk.
Euroclear UK & Ireland Transaction Reporting Service Member firms will wish to note the contents of Euroclear UK & Ireland’s Operational Bulletin 2016-198 published on 20th December 2016 which confirms that the CREST transaction reporting service will close on Sunday 31st December 2017. The existing service will continue to be provided up until then. All affected clients will be contacted directly to ensure a smooth decommissioning of the service.
Industry Consultation Paper: Asset Transfers and Re-registrations This is a reminder that firms are encouraged to read and respond to the industry consultation paper on improving pension and investment transfers and re-registrations as flagged in the last WMA Bulletin and the last WMA Update. Deadline for responses is 31st January 2017. Those firms who prefer responding via WMA can do so to Andy Thompson.
New Qualified Intermediary Agreement On 30th December 2016 the US Internal Revenue Service published the finalised Qualified Intermediary (QI) Agreement in Revenue Procedure 2017-15 . QIs have until 31st March 2017 to apply or submit a renewal application for QI status in order to be treated as a QI from 1st January 2017. WMA has organised some free CPD seminars in London, Edinburgh, Glasgow, Liverpool and Manchester in early February to provide members with updates on the Common Reporting Standard and the new QI Agreement. HMRC, Deloitte and KPMG will be involved. Book your place on the WMA website.
Anti-Money Laundering Directive The Council of Member States agreed in mid-December on final amendments to the AMLD that allow it to move forward to trilogues to negotiate the final level 1 text. The main issue of controversy remains access to beneficial ownership registers, which the Council believes should be limited to requests "based on legitimate interest" instead of the Commission's proposal for full public access. The Council text allows Member States to go beyond the "legitimate interest" limitation in their own jurisdiction provided appropriate standards of proportionality and personal privacy are adhered to (although some states believe the Council’s position does not limit access enough). Trilogue negotiations to agree the final text will start early in 2017.
Packaged Retail and Insurance-based Investment Products (PRIIPs) The Chairs of the European Supervisory Authorities (ESAs) wrote on 23rd December to the European Commission about amendments to the PRIIPs Regulatory Technical Standards (RTS). They did not provide a unanimous opinion because the European Insurance and Occupational Pensions Authority (EIOPA) Board had differing views on:
The treatment of multi-option products;
The criteria to determine whether a comprehension alert should be included in a KID;
The provisions in the RTS on the credit risk mitigation factors for insurers.
The Chairs restricted their main concerns to the amendments to the performance scenarios proposed by the European Commission. The ESAs still believe their approach in the original RTS is preferable (no reference to past performance) but if the Commission still seeks amendments one option would be to use the mean of the distribution of risk free returns, adjusted for dividend yields. The Commission will in due course submit its own version of the amended RTS to the European Parliament and Council for scrutiny.
Huntswood Financial Crime Risk Assessment Report WMA associate member Huntswood has published the report Protecting your firm, safeguarding your reputation: A good practice guide to financial crime risk assessment. The study has involved a cross section of the industry and aims to inform and support firms with their approach in this area. The document offers guidance, outlines good practice and highlights practical steps that firms can take to embed a proportionate, pragmatic and dynamic approach. Paul Scott, Huntswood’s Director of Advisory Services, will present the Report during the WMA Financial Crime Conference.
What is WMA up to? Prospectus Regulation Agreement has been reached in principle in the Prospectus Regulation negotiations to introduce for the first time in EU Prospectus law the option to disapply the €100,000 exemption limit on bond denominations below which a retail prospectus has to be issued, even to discretionary fund managers
and other institutional investors. Instead, it would allow the exemption from retail requirements for denominations of any size provided only qualified investors have access to the issues and the securities will be traded on a professional secondary market. This embeds the approach advocated by the WMA and other organisations including the LSE as a first step to eventually opening the EU corporate bond market more fully to retail investors. It also represents a move by the Council and member states towards allowing retail intermediaries to decide what vanilla bonds are suitable for their clients, thus shifting an element of the retail investor protection burden onto them.
WMA Economics Roundtable The WMA ran its first Economic Roundtable chaired by James Ashley, Head of International Market Strategy at Goldman Sachs Asset Management. The discussion was attended by a number of member firms’ chief economist, CIOs and heads of research who discussed the economic themes that are key market drivers and what impact they will have in 2017. Some of the themes we covered were:
Policy, politics and pricing
Rising inflation
What are the key concerns for investments
A whitepaper will be published on the key findings shortly.
WMA Indices The WMA will shortly be sending out a Q&A to member firms about the nature of the Indices. This Review is in response to feedback from firms. This is your opportunity to shape an expanded set of Indices. Please take a moment to give us your views.
New WMA Member We are delighted to welcome Farley & Thompson Stockbrokers to the WMA Membership.
What's coming up in our industry? FCA Advice Unit The FCA’s Advice Unit will re-open for applications on 3rd January 2017 to 3rd February 2017. The Advice Unit is part of Project Innovate, which aims to encourage innovation in financial services in the interests of consumers. The Advice Unit is open to firms of all shapes and sizes that are supplying or aiming to supply automated advisory or discretionary investment management services. The Unit provides regulatory feedback to firms meeting our eligibility criteria. In the first cohort of applications, nine firms met FCA’s eligibility criteria and qualified for regulatory feedback from the Unit on the automated advice models they were developing. The full announcement in FCA’s Regulation round-up can be accessed here.
What's coming up in WMA? Millennial Forum 2017 Launch Next week sees the launch of the 2017 Millennial Forum. Following on from its launch last year, the study looks to build on the research findings, engage with Millennial employees of member firms and build the alumni across member firms within the WMA. We have had a high number of applications this year with 28 Millennials taking part in this year’s study.
WMA Financial Crime Conference Join us on Thursday 26th January for WMA’s Financial Crime Conference to get up to date on the latest main developments and challenges in the financial crime domain. Hear from both WMA and key industry stakeholders in this area such as the FCA, Information Commissioner’s Office, Global Cyber Alliance and the Joint Money Laundering Steering Group.
For the 8th year running this event will provide a wide-ranging discussion and dialogue between member firms and key bodies in this area such as such as law enforcement agencies, government bodies and regulators. With thanks to our sponsors Huntswood and Lark Group and supporters FCA. Book your place today
WMA ICAAP Seminar - Earn 1.5 hours of CPD 24th January 2017 Exclusive and free to WMA members only, this seminar will appeal to all levels of staff who are responsible for, or contribute towards, their firm’s ICAAP. Firms will be aware that, as recently as September 2016, the FCA identified the ICAAP as being a ‘hot topic’ and EBA now places an obligation on the FCA to review all CRDIV firms’ ICAAPs. An inadequate ICAAP may result in the FCA imposing higher capital requirements on a firm and in the worst case scenarios a S166 review. David Yim, Partner at KPMG LLP, will provide feedback on the common mistakes and emerging issues that he has identified in assisting firms prepare their ICAAP or respond to feedback from the FCA. Book your place here For more information on many of the articles above visit the WMA Members Area of our website. If you have queries you can also contact the relevant WMA Staff Member. If you have forgotten, or do not have your WMA log in
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