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Clifford Chance

The UK temporary permissions regime – how EU27 funds can continue to be marketed in the UK on a no deal Brexit

The Italian Council of Ministers has approved a new law decree creating an 18-month temporary regime for UK firms engaging in regulated business in Italy and Italian firms engaging in regulated business in the UK. The temporary regime will become effective, if there is a no-deal Brexit, on the day the UK leaves the EU (for convenience, the 'exit date'). The new regime aims to mitigate the main 'cliff-edge' impacts and disruption that could have ensued under Italian law following the sudden loss of the EU passport rights in a no-deal Brexit.


16 January 2019

The UK temporary permissions regime: How EU27 funds can continue to be marketed in the UK on a 'no-deal Brexit'

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.



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