We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:
COLOMBIA OUT OF BANK’S COUNTRY OF ESTABLISHMENT (DEF, RS, BT & RT)
|SOURCE OF CHANGES||ANSWERS|
|New Position of the Authorities||No|
|Evolution of Expert’s interpretation||Yes|
Regulatory Template, Regulatory Summary and Behaviour Template
The Country Manual has been reviewed together with our local counsels to ensure that the content of all the documents remains accurate and up to date. There have been no major material changes or modifications. Based on advice from our counsel, we have clarified that Colombian regulation generally recognizes reverse solicitation as an exception to the general rules for promoting and providing of financial services in and into Colombia subject to certain conditions. The respective changes have been inserted in the RT, RS and BT.
Some comments/conditions have been reworded, additional references to applicable law/regulation have been made in order to provide more clarity and to reflect the current regulatory situation more accurately. Further non-material changes have been made throughout the documents.
Implications for business relations with third parties
With respect to the provision of documentation to the EAM (such as documentation on the Bank’s banking and investment services, investment research and financial analysis or recommendation lists), our Country Manual now distinguishes between the provision to the EAM for remittance to the end client on one hand and the provision to the EAM for the EAM’s own professional purposes on the other hand. The answers have been amended accordingly.
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 “COLOMBIA” 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.
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