Legal Updates

The FCA has reopened the window for applications under the Temporary Permissions Regime (TPR). The notification window for registrations under the TPR closes on 30 December 2020. Notifications should be submitted via the FCA Connect system on or before that date.

Any fund managers that wish to update an existing TPR application (to include additional sub-funds or AIFs) should email recognisedcis@fca.org.uk by the end of 9 December 2020 at the latest confirming their intention to update and including their FRN.

While the FCA will acknowledge the request to update a notification, it will not be possible to submit a revised notification until after 14 December 2020 at which stage the FCA will advise what steps should be taken. Fund managers should only submit their updated notification when they are certain that all the correct funds are included. Updated notifications must be received before the end of 30 December 2020.

Fund managers should continue to follow the current process via their home member state regulator for registering new funds and should allow sufficient time for notifications to be received and processed by the FCA to ensure that any new funds are eligible for the TPR.

If new UCITS sub-funds or AIFs have been added to a fund manager’s population since an earlier notification was submitted, the new funds will not be included in the temporary marketing permission regime unless fund managers request to update their notification and include them in that updated notification.

Further information on the TPR and how to register is provided on the FCA website
https://www.fca.org.uk/brexit/temporary-permissions-regime-tpr