Responses and Representations

• CMA investment consulting and fiduciary management market investigation: Response to Issues Statement - 12 October
• FCA CP17/18: Consultation on implementing market study remedies - 28 September
• FCA Retirement Outcomes Review Interim Report - 15 September
• FCA Investment Platforms Market Study: Response to Terms of Reference - 8 September
• DWP Review: Automatic enrolment - 22 March
• HMRC Consultation: VAT Grouping - 27 February
• FCA Asset Management Market Study: Response to Interim Report - 20 February
• BEIS Green Paper: Corporate Governance Reform - 17 January
• FCA Paper: Our Future Mission - 30 January
• FCA DP16/4: Overall responsibility and the legal function - 6 January
• ESMA Consultation: MiFID II Product Governance / Target Market draft guidelines - 5 January
• FCA CP16/30: Transaction cost disclosure - 4 January

• ESMA consultation: RTS/ITS for trade reporting under the Securities Financing Transactions Regulation - 2 December
• PIOB Consultation: 2017-2019 Strategy - 23 November
• Commission Consultation: Barriers to cross-border fund distribution - 9 October
• FCA CP16/18: Changes to disclosure rules in the FCA handbook to reflect the direct application of the PRIIPs regulation - 19 September
• DfE Consultation: Apprenticeship Funding Proposals - 5 September
• HMT consultation: Reform of substantial shareholdings exemption - 18 August
• HMT and HMRC consultation: Tax deductibility of corporate interest expense - 4 August
• FCA consultation: UCITS V Level 2, SFTR and consequential changes to the Handbook - 20 July
• HMRC consultation: Corporate criminal offence of failure to prevent criminal facilitation of tax evasion - 11 July
• ESMA Discussion Paper: UCITS Share Classes - 6 June
• Home Office Consultation: Action plan for anti-money laundering - 2 June
• HMT Review: AML/CFT Supervision - 2 June
• IAASB: Enhancing audit quality in the public interest - 25 May
• OECD discussion draft on treaty residence of pension funds - 5 April
• ESMA Consultation: Transaction reporting, reference data, record-keeping and clock synchronisation under MiFIR - 24 March
• IA letter: EU Commission on liquidity calibration methodology in MiFID II - 24 March
• EC Green Paper: Retail financial services - 18 March
• HMT Consultation: National Infrastructure Commission - 17 March
• EU Commission on the use of ISIN as an instrument identifier for OTC derivatives under MiFIR/D II - 14 March
• Simple, Transparent and Standardised (STS) securitisation: Joint paper - 3 March
• LGPS Consultation: Revoking and replacing the LGPS (Management and Investment of Funds) Regulations 2009 - 19 February
• FCA CP15/38: Delaying disclosure of inside information - 19 February
• Money Advice Service consultation: 2016/17 Business Plan - 18 February
• FCA CP15/35: Implementing the Market Abuse Regulation - 4 February
• FCA CP15/42: Quarterly Consultation Chapters 2, 4 & 6 - 4 February
• ESA Discussion Paper: PRIIP KID - 1 February
• EU Commission: Call for Evidence - EU regulatory framework for financial services - 29 January
  • Letter
  • Full response
• ESA consultation: PRIIPs - 29 January
• EBA consultation: Risk Based Supervision Guidelines - 22 January
• EBA consultation: Risk Factor Guidelines - 22 January
• HMT consultation: Tax deductibility of interest expense - 14 January
• EC consultation: Common Consolidated Corporate Tax Base (CCCTB) - 8 January
• European Commission Review of EuVECA and EuSEF Regulations - 7 January

• Financial Advice Market Review (FAMR) - 22 December
• FCA Asset Management Market Study Terms of Reference - 18 December
• IASB Request for Views: 2015 Agenda Consultation - 17 December
• FRC Consultation: Enhancing Confidence in Audit - Proposed Revisions to the Ethical Standard, Auditing Standards, UK Corporate Governance Code and Guidance on Audit Committees - 17 December
• BIS Consultation: Technical Amendments - 11 December
• FCA CP15/27: Part III Chapters 7 & 8 - 7 December
• FCA Consultation: Removing the requirement to produce Short Reports - 2 December
• IFRS Foundation: Trustees' Review of Structure and Effectiveness - 30 November
• IASB ED on the Conceptual Framework - 24 November
• LEI Regulatory Oversight Committee: Consultation on collecting parent entity data - 16 November
• FCA CP15/27: Part 1 - UCITS V Implementation - 9 November
• ESMA consultation: Draft RTS for ELTIF Regulation - 19 October
• IOSCO consultative report: Harmonisation of key OTC derivatives data elements other than UTI and UPI - 9 October
• HMRC consultation: Tackling offshore tax evasion - 8 October
• FCA CP15/27: Part II - ELTIF Implementation - 5 October
• EIOPA Consultation: Pan-European Personal Pension product - 5 October
• CPMI-IOSCO consultative report: UTI harmonisation - 30 September
• Strengthening the incentive to save: A consultation on pensions tax relief - 30 September
• FCA DP15/5: Smarter consumer communications - 25 September
• FCA Project Innovate: Call for input - 8 September
• PCAOB supplemental request for comment: Rules to require disclosure of certain audit participants on a new PCAOB form - 1 September
• FRC consultation on the Audit Firm Governance Code: A review of its implementation and operation - 27 August
• Work & Pensions Select Committee inquiry on Pension freedom guidance and advice - 27 August
• ESA consultation: Key Information Documents for PRIIPs - 17 August)
• EC consultation: OTC derivatives, central counterparties and trade repositories - 14 August
• EIOPA consultation: Identification and calibration of infrastructure investment risk categories - 9 August
• FRC DP: Quality of reporting by smaller listed and AIM quoted companies - 30 July
• FCA consultation: Investing in authorised funds through nominees (CP15/20) - 16 July
• ESMA consultation: No.4 - clearing obligation under EMIR - 15 July
• ESA consultation: Draft RTS - Risk mitigation for uncleared OTC derivative contracts - 10 July
• ESMA consultation: Draft guidelines for the assessment of knowledge and competence - 10 July
• HMT consultation on transposition of MiFID II - 19 June
• EBA Guidelines on limits on exposures to shadow banking entities - 19 June
• OECD follow up consultation on BEPS Action 6 (preventing treaty abuse) - 17 June
• OECD revised discussion draft on BEPS Action 7 (preventing the artificial avoidance of PE status) - 12 June
• EBA CP2015/03: Draft Guidelines on sound remuneration policies - 3 June
• FSB consultation on assessment methodologies - 29 May
• FCA DP15/3: Developing our approach to implementing MiFID II conduct of business and organisational requirements - 26 May
• EU Commission consultation on Capital Markets Union (CMU) - 13 May
• EU Commission consultation on Securitisation - 13 May
• EU Commission consultation on the Prospectus Directive - 13 May
• ESMA consultation: Operation of the buy-in regime - 6 May
• FCA CP15/08: Chapter 4 AIFMD Handbook Changes - 5 May
• Call for Evidence: Transaction Costs Disclosure: Improving Transparency in Workplace Pensions - 4 May
• Minimum alternative tax - 17 April
• ESMA Discussion Paper on the Share Classes of UCITS - 27 March
• FCA CP14/30: Improving complaints handling - 13 March
• ESMA Consultation on MiFID II / MiFIR - 3 March
• Technical Standards under the CSD Regulation - settlement discipline - 19 February
• Technical Advice under the CSD Regulation - penalties for settlement fails - 19 February
• Discussion paper on Key Information Documents for Packaged Retail and Insurance-based Investment Products (PRIIPs) - 18 February
• ESMA consultation on the technical standards on reporting under Article 9 of EMIR - 15 February
• NEST consultation on 'The future of retirement' - 13 February
• The Investment Association Position Paper: Meaningful disclosure of costs and charges - 10 February
• OECD's consultation on BEPS Action 4 (interest deductions and other financial payments) - 6 February
• The future evolution of the Investment Association sector classification system - 5 February
• HMRC consultation on Diverted Profits Tax - 4 February
• Fair and Effective Markets Review - 4 February
• FCA proposals on regulatory fees and levies for 2015/6 - 4 February
• FCA consultation on Retirement income market study: Interim Report - 30 January
• SII Tripartite Template - 14 January
• OECD consultation on BEPS Action 6 (preventing treaty abuse) - 12 January
• OECD consultation on BEPS Action 7 (preventing the artificial avoidance of PE status) - 12 January
• HMRC Consultation on changes to CTF and Junior ISA rules - 12 January

• CP14/24 Charges in workplace personal pension schemes - 30 December
• HMT consultation on including peer-to-peer loans within an ISA - 16 December
• DWP consultation on DC governance and the charge cap - 17 November
• DWP Command Paper: Better workplace pensions: Putting savers' interests first - 14 November
• IMA Submission on the Autumn Statement - 11 November
• Social media and customer communications: The FCA’s supervisory approach to financial promotions in social media - 6 November
• EU Questionnaire on Effects of Using IFRS in the EU - 6 November
• Scotland: The Smith Commission's work on the devolution of powers - 31 October
• Takeover Panel: Post offer undertakings and intentions statements - 24 Ocober
• FCA CP14/16: Proposed rules for independent governance committees - 14 October
• FCA Wholesale sector competition review - 9 October
• FCA GC14/3: Retail investment advice - Clarifying the boundaries and exploring the barriers to market development - 7 October
• European Commission proposals for a Revised Shareholder Rights Directive - 25 September
• FCA CP 14/11: Retirement reforms and the guidance guarantee - 22 September
• Removing the Transparency Directive’s requirement to publish interim management statements - 4 September
• Competition and Markets Authority consultation on the Draft Order on Audit Services  - 28 August
• FCA CP14/8: Quarterly Consultation No. 5 - Chapter 7 - 6 August
• ESMA Consultation Paper on MiFIR/D - 1 August
• ESMA Discussion Paper on MiFIR/D  - 1 August
• IASB ED 2014/1: Disclosure initiative proposed amendments - 25 July
• ESAs CP on draft Regulatory Technical Standards covering the risk-mitigation requirements for non-centrally cleared OTC derivatives - 14 July
• DCLG Consultation on Local Government Pension Scheme - 11 July
• Bank of England/ European Central Bank paper on Securitisation - 4 July
• Proposed Revisions to the UK Corporate Governance Code - 27 June 2014
• Freedom and choice in pensions - 11 June
• European Commission consultation on FX (Spot versus Forward) - 2 June
• Better workplace pensions: Further measures for savers - 29 May
• EBA draft guidelines on the remuneration benchmarking exercise - 1 May
• EBA draft guidelines on the data collection exercise regarding high earners - 1 May
• FRC FRED 54: Draft Amendments to FRS 102 - 30 April
• PRA consultation on application of clawback to vested variable remuneration - 28 April
• EBA paper on the impact on capital from the deduction of pension assets and IAS 19 - 11 April
• EBA paper on CRA 2 implementation - 10 April
• FCA CP14/4: Quarterly Consultation No. 4 - 8 April
• FSB/IOSCO consultation on NBNI G-SIFI - 7 April
• EBA draft guidelines on disclosure of encumbered and unencumbered assets - 24 March
• Banking Standards Review - 7 March
• FCA consultation on dealing commission rules - 25 February
• Representations for Budget Report 2014 - 13 February
• FCA consultation on short reports and other communications - 6 February
• ESMA Guidelines on ETFs and other UCITS issues - 30 January
• ESMA Discussion Paper on the Market Abuse Regulation - 27 January
• EU powers ‘Balance of Competences’ Review – Freedom of Services and Capital - 22 January
• Fiduciary duties of investment intermediaries - 22 January
• A Review of the Conceptual Framework for Financial Reporting  - 15 January
• FCA CP13/14: Regulatory Fees - 8 January

• EBA consultation on draft notional discount rate for bonuses and scope of Code staff - 17 December
• Joint ESA consultation on Mechanistic references to credit ratings - 12 December
• IAASB ED: Reporting on audited financial statements - 3 December
• Better workplace pensions: A consultation on charging - 28 November
• CRD IV: Reporting - 26 November
• CRD IV: Countercyclical capital buffers - 29 October
• European Banking Authority paper on draft Regulatory Technical Standards (RTS) - 25 October
• CRD IV - country by country reporting - 18 October
• FCA CP13/5: Review of the client assets regime for investment business - 18 October
• Recovery and resolution of non-bank financial institutions - 15 October
• Recovery of finncial market infrastructures - 10 October
• Banking Reform: Draft Secondary Legislation - 7 October
• FCA CP13/9: Quarterly Consultation No.2 - 4 October
• European Banking Authority paper on draft Regulatory Technical Standards (RTS) - 30 September
• FCA CP 13/06: Implementation of CRD IV - 30 September
• DCLG Call for Evidence on the Future Structure of the Local Government Pension Scheme - 27 September
• IASB Exposure Draft, 2013/6: Leases - 27 September
• DWP call for evidence: “Quality standards in workplace defined contribution pension schemes" - 18 September
• BIS DP: Transparency & Trust: Enhancing the Transparency of UK Company Ownership and Increasing Trust in UK Business - 16 September
• HMRC consultation on the taxation of corporate debt and derivative contracts - 2 September
• Competition Commission: Statutory Audit Services – provisional decisions on remedies - 23 August
• HMRC consultation on taxation of LLPs and other partnerships - 12 August
• European Banking Authority paper on draft Regulatory Technical Standards (RTS) - 12 August
• New regulations for securitisation under CRD IV - 12 August
• HMT consultation on allowing transfers of CTFs to Junior ISAs - 6 August
• OECD questions on exchange of information - 26 July
• IASB paper on Financial Instruments: Expected Credit Losses - 16 July
• Guidelines on reporting obligations under AIFMD - 1 July
• ECON consultation on Coherence of EU legislation - 20 June
• IASB Exposure Draft: Classification and Measurement: Limited Amendments to IFRS9 - 31 May 2013
• IOSCO consultation on Principles for Financial Benchmarks - 16 May
• FCA CP13/09: Implementation of the AIFMD - Part 2 - 10 May
• FRC’s consultation on its proposed revisions to ISA (UK and Ireland) 700 - 9 May
• FRC consultation on the Sharman Panel’s review - 28 April
• CIIA paper on Effective Internal Audit in the Financial Services Sector - 8 April
• Competition Commission Market Inquiry - Statutory Audit Services for Large Companies - 25 March
• ESMA call for evidence on evaluation of the Short Selling Regulation - 18 March
• BCBS-IOSCO consultation –collateral and margin for derivatives trades - 15 March
• Representations for Budget Report 2013 - 8 March
• FSA consultation on UK Tax Transparent Funds - 5 March
• HMRC consultation on Implementing the UK-US FATCA Agreement - 28 February
• HMT consultation on AIFMD - 27 February
• HMT review on competences between United Kingdom and European call for evidence - 22 February
• ESMA consultation on Principles for Financial Benchmarks - 15 February
• FSA CP13/1: FSCS Funding Model Review - 13 February
• IOSCO consultation on Financial Benchmarks - 11 February
• FSB observations on remuneration practices  - 11 February
• Money Advice Service: Draft business plan - 11 February
• HMRC: Double Tax Treaty Network Review 2013/14 - 6 February
• FSA CP12/35: Temporary Product Intervention Rules - 4 February
• DWP: Supporting Automatic Enrolment - 28 January
• BIS: Kay Review - 25 January
• FSA CP12/36: The regulation and supervision of benchmarks - 16 January
• FSA CP12/25 : Enhancing the effectiveness of the Listing Regime - 9 January
• FSA CP12/28: Regulatory fees and levies - 8 January

December

Department for Business, Energy & Industrial Strategy: National Security& Investment Bill: Mandatory Notification Regime - 22 December

HMRC: ISAs and Authorised Open-Ended Property - IA/AREF Joint Response - 11 December

November

Basel Committee on Banking Supervision: Principles for Operational Resilience - 6 November

FCA: CP 20/15 Liquidity mismatch in authorised open-ended property funds - 3 November

October

DWP: Improving outcomes for DC pension scheme members - 29 October

IOSCO: Use of AI & ML by asset managers - 26 October

HMT: Consultation on a new Economic Crime Levy - 13 October

IOSCO: Principles on Outsourcing - 1 October

FCA: CP20/3 Proposals to enhance climate related disclosures by listed issuers - 1 October

September

FCA: Guidance on Vulnerable Customers - 30 September

FCA: DP20/02 - A new UK prudential regime for MiFID investment firms - 25 September

FCA: Open Finance - 25 September

IIGCC: Net Zero Investment Framework - 25 September

FCA: CP20/09 - Driving value for money in pensions - 24 September

FCA: Operational Resilience - 24 September

Response to EBA consultations on the new Prudential Regime for Investment Firms - 4 September

• Final response to EBA/CP/2020/06
• Final response to EBA/CP/2020/07
• Final response to EBA/CP/2020/08
• Final response to EBA/CP/2020/09

ESAs: Joint Consultation on ESG Disclosure - 1 September 

ESMA: Harmonisation of Leverage Limits under Article 25 AIFMD - 1 September

August

European Commission CP: AML Action Plan - 25 August 

DWP: Call for evidence on the review of the DC default fund charge cap and standardised cost disclosure - 20 August

HMT: Consultation on updating the UK’s Prudential Regime before the end of the Transition Period - 19 August

July 

EU CP: Renewed Sustainable Finance Strategy - 15 July

DCMS: Expansion of the dormant assets scheme

EC consultation on amendments to MiFID, UCITS & AIFMD Draft Delegated Acts- 6 July

• Amendments to Delegated Regulation (EU) No 2312013- AIFMD
• Amendments to the Delegated Regulation (EU) 2017_565 
• Amendments to the Delegated Directive (EU) 2017_593 
• Amendments to Directive 201043EU- UCITS

DWP Consultation: Aligning your pension scheme with TCFD - 2 July

June 

EU CP: Non-Financial Reporting Directive - 11 June 2020

May

HMT: A Consultation on the Reform to Retail Prices Index Methodology - 15 May

March

OECD: BEPS Action 13 – Country by Country Reporting (CbCR) - 6 March

February

HMRC CP: Broadening Application of 5MLD to Trusts - 21 Feb

Representation for Spring Budget 2020 - 7 Feb

Standardisation of Reject Codes in FX Trading - 5 Feb

January

ESAs Joint Consultation Paper concerning amendments to the PRIIP KID - 13 Jan

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