FCA’s latest Policy Development Update indicates we can expect its fourth consultation paper on MiFID 2 implementation soon, maybe before the end of the year. It then promises feedback on consultations to date during the first half of 2017 – and will have to make its final rules by July to meet the transposition deadline. It will also be focusing on consumer credit, consulting on reporting provisions and creditworthiness assessments. Meanwhile, its latest quarterly consultation proposes, among other changes, changes to DEPP to set out its decision making process under the MLR, and to COBS on adviser charging for vertically integrated firms. These latter changes are driven by the Financial Advice Market Review, which recommended clearer guidance on the meaning of “long term” in relation to payback periods for investment.
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