If your firm wants to continue to advise on, arrange and deal in structured deposits after MiFID II takes effect, this will mean a change to your firm’s scope of permission to include this investment type. Up until 2nd January 2018 there is a special process in place, which just involves notifying the FCA of your intention. Firms that already have the following permissions for other investment types can use this notification process:
- arranging deals in investments (Article 25(1) RAO)
- making arrangement with a view to transactions in investments (Article 25(2) RAO)
- managing investments (Article 37 RAO)
- advising on investments (Article 53 RAO)
The process is to complete a form and e mail it to the FCA at the address on the form; we’ll keep the form on the Haven RM website until January. After 2nd January 2018 this process will be discontinued so if you want to continue activity in relation to structured deposits from 3rd January 2018 the process will be a full variation of permission.
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The above is the lead article in our latest monthly News Notes – July 2017. Other topics in this edition include:
- Changes 2018
- Complaints Handling Procedure
Haven Risk Management : FCA Compliance Consultants