On September 26, the UK Financial Conduct Authority (FCA) published updated draft directions under its Temporary Transitional Power (TTP). The TTP is designed to give the FCA flexibility in applying post-Brexit requirements to firms that are transitioning to the new UK regulatory framework following the UK’s departure from the EU. The draft directions would only come into effect on exit day if the UK leaves the EU without an implementation period.
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On March 23, the European Central Bank (ECB) published two guides (together, Guides):

  • a guide to assessing license applications (General Licence Application Guide) which covers the general application process and the assessment requirements regarding, for example, governance, risk management, capital; and
  • a guide to assessing financial technology (FinTech) credit institution license applications (FinTech Licence Application Guide)—intended to complement the General Licence Application Guide with a focus on FinTech entities that are considering an application for a banking license.


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On March 20, the UK government published its response (Response) to the House of Lords EU Sub-Committee on Financial Affairs report on Brexit and financial services (Report).

In the Report, which was published in December 2016, the Committee set out recommendations for the government relating to financial services, covering issues such as transitional arrangements and market access.
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