Andrew Bailey has written to Lord Myners explaining why FCA has not taken, and does not think it appropriate to take, action to establish its own requirements for liquidity standards for UCITS. The letter explains that FCA could in any event impose higher liquidity requirements than the UCITS Directive require only on UK funds, and could not change the standards relating to funds from other Member States. He also says that the intention of UCITS is that they be liquid and notes that exchange listing and liquidity are not the same thing. He is, however, in favour of considering the SEC’s new approach to create a purposive test of liquid status supported with requirements around governance and controls. And his final reason for advocating a different standard rather than a stronger version of the current one is to ensure start ups and innovative funds do not suffer because of liquidity policies.