Country Manual Private Banking
Italy LPS – Update 2024
BRP has updated its Country Manual Private Banking for Italy LPS out of Bank’s Country of Establishment (DEF, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | No |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The documents have been reviewed following consultation with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.
With the signing of the MoU between FINMA, the Bank of Italy and Consob announced on 16 August 2023, the possibility of obtaining an LPS licence to serve eligible counterparties and/or “per se” professional clients in Italy without establishing a branch/subsidiary has become a reality. However, since this is only a theoretical option at this stage, this is not discussed in any further detail in this manual.
Non-material changes
Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
Furthermore, the answers of the section “Corporate Actions” were aligned to those related to the provision of investment advice (specifically from ”Grey Zone” to “Grey Zone/No” at target and actively in remote).
Implications for business relations with third parties
Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
This gave the opportunity to better specify that the provision of documentation to the EAM for its own use should be done only upon request and remotely.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “ITALY LPS” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Geneva, August 29th, 2024