Country Manual Private Banking – United Kingdom – BRP Update 2024
BRP has updated its Country Manual Private Banking for United Kingdom out of bank’s country of establishment (DEF, RS, BT and RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The manual has been updated to reflect various regulatory changes;
- The enactment of the Financial Services and Markets Act 2023 and in particular, the introduction of a regulatory gateway for the approval of financial promotions. If a foreign firm wants to have a promotion approved by a UK authorised entity that entity will in general need to have permission from FCA to approve promotions. Intra group approval of promotions is not subject to the gateway.
- Changes to the promotional exemptions for high net worth individuals and self-certified sophisticated investors. Minor changes have been made. More extensive changes were introduced in January 2024 but have subsequently been reversed.
- The manual still applies to Swiss banks. There is a reference to the Mutual Recognition Agreement between the UK and Switzerland in the Scope section, but as the MRA has not yet been ratified Swiss banks are not as yet able to use any of the MRA access routes into the UK.
Non-material changes
The comments for Grey zone/YES answers in relation to debit and credit cards have been amended to emphasise that no cards should be issued in the UK.
For onsite offering of Lombard credit there is an additional comment that the credit institution should avoid entering into credit agreements in the UK.
Implications for business relations with third parties
The documents having been reformatted onto the latest template, this section now provides for more answers, better distinguishing between the provision of documentation to the EAM for its own use and provision of documentation for its subsequent distribution to end-clients.
Regulatioon 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 “UK” 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, May 28th, 2024