Country Manuals Credits –
We would like to inform you that BRP has updated its COUNTRY MANUALS CREDITS for the following jurisdictions:
ITALY OUT OF CREDIT INSTITUTION’S COUNTRY OF ESTABLISHMENT (RT, BT & Def)
| SOURCE OF CHANGES | ANSWERS |
| Law/Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | No |
Regulatory Template
Material changes
We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.
The answers for remote interaction on reverse solicitation have been modified from YES to Grey zone/YES to align with CM PB and take into consideration the requirement of reverse solicitation to be duly documented.
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.
Behaviour Template
The answers in the BT have been aligned to those contained in the RT. In particular, the answers in case of remote interaction on reverse solicitation have been modified from YES to Grey zone/YES to align with CM PB and take into consideration the requirement of reverse solicitation to be duly documented.
Definitions and Concepts
The document Definitions and Concepts now includes a Concordance Table. This Table is designed to help the users of the Country Manual Credits easily recognize existing or potential interactions between the rules of different types of credits.
For more information, please contact us: info@brpsa.com
Best regards,