| Independent Portfolio Manager/Advisor – We would like to inform you that BRP has updated its COUNTRY MANUAL INDEPENDENT PORTFOLIO MANAGER/ADVISOR (EAM) for the following jurisdiction: ITALY 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
We have reviewed the documents and can confirm that there have been no relevant regulatory changes since the last publication of this Country 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. In particular we highlight the following:
Negotiation Phase
> The condition that onboarding was done in compliance with the local-cross border rules was added in case of remote interaction on Bank’s initiative in order to collect relevant supporting documents and the wording of the specific explanation amended accordingly.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the EAM 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 EAM BT SHORT COMP” and “ITALY” 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
Best regards,