| Country Manuals Private Banking – We would like to inform you that BRP has updated its COUNTRY MANUAL PRODUCTS 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 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 two cases the answers were slightly modified, more precisely:
Negotiation Phase
– The answers for the active collection of information required for client’s investment profile via remote means of communication has been amended (from Grey zone to Grey zone/YES), subject to the condition that onboarding was done in compliance with the local cross-border rules.
Reporting
– The answers regarding on-site reporting to a client on managed account performance has been amended from Grey zone/YES to Grey zone and the comment aligned to the one of CM PB Italy, since the LPS doesn’t provide any additional room with reference to investment services.
Implications for business relations with third parties
There have been no substantial changes to the answers when a Bank cooperates with third parties.
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
Best regards,