Clifford Chance
The UK temporary permissions regime: How EU27 funds can continue to be marketed in the UK on a 'no-deal Brexit'
16 January 2019
The UK Government has legislated for a Temporary Permissions Regime (TPR) enabling EU27 managers who are currently marketing funds into the UK under the AIFMD and UCITS marketing passports to continue marketing those funds for a limited period after 29 March 2019 (exit day) if there is a 'hard Brexit'.
EU27 managers must notify the FCA if they intend to use the TPR. It is expected that the FCA will accept notifications from 'early January' and that the notification window will close prior to exit day. The FCA is currently consulting on how the TPR regime should work in practice, so further details are expected shortly.
