Country Manuals Private Banking –
Dear Client,
We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING 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
The documents have been reviewed following consultation with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.
However, as we have highlighted in our recent webinars and training sessions on Italy, the signing of the MoU between FINMA, the Bank of Italy and Consob is a new factor to consider in the management of cross-border risk. It is likely that the Italian supervisory authorities will be able to request and have access to new statistical data on cross-border activities of Swiss banks. In practice, this means that although the rules and assessment methods should not change, Italian supervisory authorities will have an additional tool to monitor the activities of Swiss banks.
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.
Furthermore, the answers of the section “Corporate Actions” were aligned to those related to the provision of investment advice (specifically from ”Grey Zone” to “Grey Zone/No” at target and actively in remote).
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. This gave the opportunity to better specify that the provision of documentation to the EAM for its own use should to be done only upon request and remotely.
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” 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,