Update BRP Country Manual Products
United Kingdom
| SOURCE OF CHANGES | ANSWERS |
|---|---|
| Law/Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | Yes |
Definitions & Concepts, Regulatory Overview and Behaviour Template
The Country Manual has been reviewed to ensure that the content of all the documents remain accurate and up to date.
Material changes
In alignment with the Country Manual Private Banking (CM PB), the active provision of macroeconomic information/reports and investment research and financial analysis documents/reports is only permitted on an occasional basis onshore in the UK (at target) provided that there is no communication of a financial promotion, and that the information/reports do not constitute investment advice. The Country Manual Products Behaviour Template (CM P BT) therefore now provides the answer “Grey zone/YES” in the relevant onshore scenario;
In further alignment with the CM PB, publications and other marketing material referring to specific financial products made on a generic basis or based on the specific investment profile of the recipient, is permitted only on an occasional basis onshore in the UK (at target) provided that a financial promotion exemption is available. The CM P BT therefore now provides the answer “Grey zone/YES” in the relevant onshore scenario;
In addition, it is highlighted that any provision of execution only services and investment services by foreign (unlicensed) service providers onshore in the UK (at target) are also only permitted on an occasional basis. Accordingly, the CM P BT now provides the answer “Grey zone/YES” in the relevant onshore scenarios;
To better reflect the evolving interpretation of the current regulatory framework, please note that the CM P BT now provides the same approach for “reverse solicitation limited to a request” and for “reverse solicitation not limited to a request”, as the UK does not distinguish between types of “reverse solicitation”.
Non-material changes
Some comments and content have been slightly reworded/added in the CM, without introducing substantive changes in order to better reflect the regulatory situation/current interpretation of the regulatory framework.
For more information, please contact us: info@brpsa.com
Geneva, May 9th, 2025