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The FCA’s Temporary Permissions Regime, TPR for inbound passporting EEA firms and funds

The FCA has issued Consultation, CP18/29 inviting feedback on their proposed temporary permissions regime, “TPR” which will allow EEA firms and investment funds to continue business activity in the UK where there is no agreement or transition period in place post Brexit date, 29th March 2019.

Under the proposed TPR, a fund manager cannot:

  • Add any new schemes to the funds in the TPR
  • Add new sub-funds to umbrella schemes
  • Change or extend the customer category to be marketed while the scheme is in TPR. 

Next Steps:

  • Is your business impacted by the TPR?
  • Responses to this consultation are required before 7th December 2018
  • Final Rules anticipated in early 2019 ahead of Brexit date, 29th March 2019
  • Have you considered the extent of Brexit impacts to your business model?