Post on 02-Aug-2020
EU Regulatory Update -
IMAS 5th Regulatory/Legal
Round-up Forum
Jason Valoti
Partner, Simmons & Simmons
Jonathan Quie
Of Counsel, Simmons &
Simmons
9 February 2018
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EU Regulatory Update - key issues for non-EU
fund managers
MiFID2 - Implementation update
EU PRIIPS Regulation
EU Benchmark Regulation
EU General Data Protection Regulation
What we
are going to
cover today
MIFID2
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MiFID2 Implementation
MiFID2 came into effect on 3 January 2018
– Comprises Regulation (EU) No 600/2014 (MiFIR) and Directive 2014/65/EU (also
MiFID2)
– 5 Delegated Acts, 35 RTS + 11 ITS adopted so far, more to come
– Lots of Level 3 measures being issued by ESMA (7 Guidelines, 8 Q&As/FAQs, 6
Opinions and 10 Instructions at latest count)
– EU Member State implementation – gold plating
– Third country reactions
Very broad application
– Applies across financial services industry – covers investment banks, private banks,
brokers, wealth managers, asset managers, exchanges, markets, data providers
– Direct and indirect impact on Non-EU third country firms
Implementation generally smoother than anticipated
– Some technological teething issues and other common difficulties
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Some MiFID2 Themes/Trends affecting APAC
Greater disclosures of costs/charges and other information for funds
– Some non-EU funds opting out of EU fund of funds investments
– New target market information for specific funds leading to them being removed from
certain fund platforms
– Some EU fund managers dropping their MiFID status (i.e. focusing on fund
management only, which is not directly caught by MiFID2)
Contraction of EU research industry connected to research unbundling
– Much focus on commission sharing arrangements in APAC
– Need for additional local licences? e.g. Japan/South Korea/Taiwan?
– Market Commentary/Bloomberg Access?
Many consent forms provided and terms of business updated
Some exchanges moved out of EU (e.g. some ICE futures)
MiFID2 product governance legends
– Still trying to get an industry standard position (ICMA drafts)
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Some Implementation Difficulties affecting APAC
Not all Member States have implemented all MIFID2 (~14 of 28 have not)
Legal Entity Identifiers (LEIs) behind schedule – 6 months grace
Some technology issues
– Connectivity issues between FCA (and other competent authorities) and approved
reporting mechanisms
– Teething issues with new IT platforms needing temporary manual work-arounds
Some ISIN discrepancies (e.g. FX forwards confusing cash v physical)
Derivatives trading issues
– Uncertainty on package orders
– Some traders uncertain if particular OTFs are authorised
– Some brokers reporting trading OTC when in fact SI
Regulatory interpretation uncertainties
– Flaws in methodology for calculating fund costs
– Some events badged as MiFID2 compliant but not consistent with inducement rules
EU Packaged Retail and
Insurance-based Investment
Products Regulation
(the “PRIIPs Regulation”)
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EU PRIIPS Regulation: Overview
Came into force on 1 January 2018
The principal requirement of the PRIIPs Regulation is the provision of a key
information document (KID) to EU retail investors investing in PRIIPs.
– KIDs must be in a prescribed format, presenting various data on costs, risks
and rewards, according to set methodologies.
– The PRIIPs ‘Level 2’ Regulation1 sets out a template for the KID (not to
exceed three pages) and prescriptive requirements on the information that it
must contain.
UCITS managers are exempt from the requirement to produce a KID for their
UCITS funds until at least December 31, 2019.
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Application to Non-EU Fund Managers
A PRIIP is an investment where, regardless of its legal form, the amount
repayable to the retail investor is subject to fluctuations because of exposure to
reference values or to the performance of one or more assets that are not
directly purchased by the EU retail investor.
– An investment fund share or unit would typically be classified as a PRIIP.
Although certain investment funds may typically be marketed only to
professional investors, EU retail investors might nonetheless be invested in
such funds. This could be the case where, for example, nominee vehicles in the
name of EU private banking or wealth management firms invest in the fund on
behalf of beneficiaries that are EU retail investors.
Although the PRIIPs Regulation is not explicitly stated to apply to non-EU fund
managers, the European Commission have stated that the PRIIPs Regulation
will apply to all PRIIP manufacturers, including non-EU manufacturers, if the
PRIIP is made available to EU retail investors.
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What is a ‘Retail Investor’?
A retail investor, for purposes of the PRIIPs Regulation, is a ‘retail client’ as
defined under MiFID2
– in essence, a retail client is any client that is not a professional client.
‘Professional client’ is in turn defined under MiFID II to mean certain clients
that are professional by their status (e.g., financial institutions, pension
funds, governments, central banks and certain large entities), or retail clients
that elect (or ‘opt-up’) to be treated as professional clients.
In order for retail clients to be classified as professional clients, they must be
assessed as having expertise, experience and knowledge such that they are
capable of making the relevant investment decisions and understanding the
risks involved.
It should be noted that, under MiFID II, local authorities will be classified as
retail clients rather than professional clients.
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Obligations of PRIIPs Manufacturers
The manufacturer of a PRIIP has the legal obligation to produce the KID.
– A fund manager would be considered to be the ‘manufacturer’ of its funds;
accordingly, to the extent that a fund is made available to EU retail investors,
the relevant fund manager will be required to produce a KID for that fund.
Separately, any person advising on, or selling, a PRIIP to EU retail investors
must provide a KID to those retail investors.
– Such a person might be the fund manager itself, or any distributor of the
fund. This will include EU financial institutions that are advising, or otherwise
acting for, EU retail investors.
The PRIIPs Regulation is not entirely clear on whether KIDs need to be
provided to existing EU retail investors in a fund.
– The prevailing market view appears to be that KIDs only need to be
provided to existing investors where such investors make new investments
from the time the PRIIPs Regulation applies; i.e., from January 1, 2018.
Equally, a KID would need to be provided to any new EU retail investors
investing in new or existing funds from January 1, 2018.
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Next Steps
Fund managers that do not wish to prepare a PRIIPs KID will need to:
– ensure that any EU retail investors already invested in their funds either
make no further investments beyond January 1, 2018, or (where possible)
opt-up to be treated as professional clients before making any further
investments.
– consider amending their offering and subscription documents to make clear
that the fund is available only to professional clients (including beneficiaries
of investments made by such professional clients).
Fund managers that wish to continue to receive investments from EU retail
investors from January 1, 2018 onwards will need to:
– produce a KID in accordance with the PRIIPs Regulation. KIDs will need to
be published the KIDs on fund manager’s websites.
– Managers should also work with institutions distributing their funds (including
institutions that invest as nominees for underlying EU retail investors) to
coordinate the KIDs process, including establishing whether there is a need
to translate the KID into the national language of the investor.
EU Benchmark Regulation
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EU Benchmarks Regulation (“BMR”): Overview
Came into force on 1 January 2018
– Regulation (EU) 2016/1011
– Many Level 2 regulations
– Subject to transitional provisions
Introduced following regulatory investigations into manipulation of setting
financial benchmarks including LIBOR and EURIBOR
Goes well beyond IOSCO Final Report on Principles for Financial Benchmarks
(“IOSCO Principles”) published in July 2013
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The primary restriction
A supervised entity will only be permitted to use a benchmark in the EU if it is
provided by an administrator who is authorised or registered in the EU under the
BMR (BMR Art. 29, but note third-country provisions)
The list of supervised entities is very broad, including credit institutions,
investment firms, UCITS and AIFMs
The “use” of a benchmark includes:
a) issuing a financial instrument which references the benchmark
b) determining the amount payable under a financial instrument or financial contract
referencing the benchmark
c) being a party to a financial contract which references the benchmark
d) providing a borrowing rate calculated as a mark-up over the benchmark
e) determining the performance of an investment fund through an index or combination of
indices for the purpose of tracking the return thereof or defining the asset allocation of a
portfolio or computing performance fees
Authorisation/registration requires compliance with BMR provisions (BMR Art. 34)
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What is a benchmark?
A benchmark is “any index by reference to which the amount payable under a
financial instrument or a financial contract, or the value of a financial instrument
is determined, or an index that is used to measure the performance of an
investment fund with the purpose of tracking the return of such index or of
defining the asset allocation of a portfolio or of computing the performance fees”
An index is:
“any figure:
(a) that is published or made available to the public;
(b) that is regularly determined:
(i) entirely or partially by the application of a formula or any other
method of calculation, or by an assessment; and
(ii) on the basis of the value of one or more underlying assets or
prices, including estimated prices, actual or estimated interest
rates, quotes and committed quotes, or other values or surveys.”
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Example benchmarks
Interest rates: e.g. LIBOR, EURIBOR, HIBOR, TIBOR
Equities: e.g. FTSE 100, Hang Seng Index
Swap rates: e.g. ICE Swap Rate (formerly ISDAFIX)
Commodities: e.g. MSCI/GSCI indices
FX: e.g. WM/Reuters which cover multiple currency pairs
Probably not benchmarks:
– credit derivatives indices such as iTraxx/CDX as they are lists of names, though the
names are selected semi-annually based on market submissions
– … and used for pricing (e.g. credit spreads/upfront amounts and tradeable credit
fixings)
– IHS Markit is determining in line with IOSCO Principles anyway
– single price from index futures (BMR Art. 2(2)(d))
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Who is affected by BMR?
• Person having control over the provision of a benchmarkAdministrators
• Person contributing input data to an administrator for the purposes of determining a benchmark
Contributors
• Person who (a) issues a financial instrument which referencesthe benchmark; (b) determines the amount payable under afinancial instrument or financial contract referencing thebenchmark; (c) is a party to a financial contract which referencesthe benchmark; (d) provides a borrowing rate calculated as amark-up over the benchmark; or (e) determines the performanceof an investment fund through a benchmark
Users
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Benchmark significance
The extent to which administrators must comply with BMR varies according to
the significance of the benchmark.
Critical
• used as a reference for financial
instruments or financial contracts or
for the determination of the
performance of investment funds
having a total value of at least
EUR500bn; or
• based on submissions by
contributors, the majority of whom
are located in one EU member state
and is recognised as critical in that
member state by the relevant
competent authority; or
• (i) same as first point above but with
a value of EUR400bn; (ii) no or few
market led substitutes; and (iii)
cessation would have significant
and adverse consequences.
Significant
Does not satisfy all the criteria to be a
critical benchmark, but:
• is used as a reference for financial
instruments or financial contracts or
for the determination of the
performance of investment funds
having a total average value of at
least EUR50bn over a period of six
months; or
• has no or very few market-led
substitutes and its absence would
have a significant and adverse
consequences for amongst others
consumers or the financing of
households and corporations in one
or more EU member state
Non-significant
Does not fulfil the necessary criteria to
be a “critical” or “significant”
benchmark
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Benchmark requirements
Critical
• Detailed requirements set out in
BMR Title II (Arts 4 to 16), e.g.:
• 4(1) : robust governance
arrangements, identifying/
managing conflicts of interest,
discretion “independently and
honestly exercised”
• 11(1): input data “sufficient to
represent accurately and reliably
the market or economic reality”
• 12(1): benchmark methodology
“robust and reliable” with clear
rules
• 15: administrators to develop code
of conduct
• Plus:
• Mandatory administration (Art. 21)
• Mitigation of market power (Art.
22)
• Mandatory contribution (Art. 23)
Significant
• Administrator may choose not to
apply certain provisions of BMR Title
II if “the application of one or more of
those provisions would be
disproportionate taking into account
the nature or impact of the
benchmark or the size of the
administrator” (BMR Art. 23(1)
• These provisions are BMR Arts: 4(2);
4(7) (c), (d) and (e); 11(3)(b); and
15(2), e.g.:
• 4(2): “The provision of a
benchmark shall be operationally
separated from any part of an
administrator’s business that may
create an actual or potential
conflict of interest.”
• 11(3)(b): if input data from front
office, those contributors to have
“adequate internal oversight and
verification procedures”
Non-significant• Administrator may choose not to
apply even more, with no
“disproportionality” requirement
• These provisions are BMR Arts: 4(2);
4(7) (c), (d) and (e); 4(8); 5(2); 5(3);
5(4); 6(1); 6(3); 6(5); 7(2); 11(1)(b);
11(2)(b) and (c); 11(3); 13(2); 14(2);
15(2); 16(2); 16(3), e.g.:
• 7(2): administrator to designate
internal function to review and
report on compliance with BMR
• 11(3)(a): input data from front office
to be corroborated against other
sources
• 16(2): supervised contributor to
have “effective systems and
controls to ensure the integrity and
reliability of all contributions of
input data”
• 16(3): policies on use of judgment
or exercise of discretion
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Non-EU benchmarks
Third Country Provisions
Benchmarks provided by non-EU Administrators will need to be registered in the
EU by 1 January 2020 in order to be used after that date
Three modes of access:
– Equivalence
– Recognition
– Endorsement
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BMR: Impact on Fund Managers
The BMR is a significant piece of legislation for the asset management industry.
The definitions of “benchmark” and “use of a benchmark” both refer to
“investment funds” (defined in the BMR as UCITS or AIFs).
– likely many UCITS and AIFs will be brought into scope of the BMR through
their “use of a benchmark” (e.g. many tracker funds will be “using” a
benchmark).
Fund managers are also at risk of being considered “administrators” if certain
levels they produce are “benchmarks” as defined in the BMR.
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BMR: Impact in Asia
Use of many Asian benchmarks may be curtailed in EU after 1 January 2020
– Currently unlikely that any APAC jurisdiction would meet the “equivalence” test
– Difficulties with the “Recognition” and “Endorsement” regimes
– Singapore is consulting on the introduction of a benchmarks regulation regime
– HK at present has no intention to introduce a benchmarks regulation regime
Third country benchmark providers considering whether to withdraw their
benchmarks to avoid time and expense of compliance (smaller ones may not be
viable).
Contingency planning in documents means EU users already starting to move
away from use of APAC benchmarks?
EU General Data Protection
Regulation
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EU General Data Protection Regulation (“GDPR”)
The GDPR comes into force automatically in each of the EU Member States
(“EU”) on 25 May 2018.
– seeks to align and bolster the data protection regime across the EU.
– implements more stringent operational requirements for processors and
controllers of personal data
– Significantly increase the extraterritorial reach of European data privacy
legislation.
– Significantly increases penalties for non-compliance (including fines of up to
the greater of EUR 20 million or 4% of the business’s worldwide annual
turnover).
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GDPR: Key Concepts
What is “personal data”?
– data relating to a living individual (whether or not they are an EU citizen) (a
“data subject”) who can be identified from that data.
– includes both employee and investor data.
– examples of documents which contain personal data include: employment
agreements, anti-money laundering information and subscription
agreements.
Who are “data controllers”?
– organisations or persons who control personal data – they determine the
purposes for which the personal data is processed and decide what is done
with it.
– A fund’s manager and/or administrator (as applicable) would likely be
considered a controller.
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GDPR: Key Concepts
Who are “data processors”?
– organisations or persons who process the personal data in accordance with
the instructions of the controller.
– processing is defined broadly and encompasses most kinds of actions
carried out with respect to the data, including obtaining, recording or holding
the data, or carrying out any operation or set of operations on the data, or
deleting, transferring or disclosing the data.
– likely that a fund’s manager would, in the ordinary course of business,
engage third-party processors of personal data (such as e.g. fund
administrators).
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Who does the GPDR apply to?
Broadly, the GDPR applies to
– controllers and processors established in the EU as well as controllers
and processors not established in the EU where the activities the
controllers or processors carry out either involve
– (i) offering goods or services (such as interests in funds) to data subjects
in the EU, and/or
– (ii) monitoring data subjects’ behaviors in the EU.
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GDPR: Key Changes
Breach Notification:
– Data controllers are required to notify the applicable data supervisory
authority of certain data breaches without undue delay and, where possible,
within 72 hours of awareness.
– Data controllers may also be required to notify data subjects if the breach is
likely to result in a “high risk” to the rights and freedoms of individuals.
Consent:
– More detailed conditions for using consent to enable data processing,
namely consent must be “freely given, specific, informed, and
unambiguous”. In cases of sensitive personal data it must also be “explicit”.
Data Subject Rights
– Data subjects will have expanded rights including the right to port personal
data between service providers and the right to object to automated
decision-making.
– Protocols for dealing with complaints and access to data updated.
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GDPR: Impact for non-EU fund managers
There are two ways a non-EU fund manager may be brought into the scope of
the GDPR:
– if the non-EU fund manager has an establishment in the EU, then that
establishment would be subject to the GDPR. “Establishment” is not defined
in the GDPR. The determination whether a business has an establishment
in the EU must be determined based on the individual facts looking at the
nexus of the business with the EU.
– If a non-EU fund manager does NOT have an establishment in the EU, but
does either (i) offer goods or services (such as interests in the fund
manager’s funds) to data subjects in the EU, or (ii) monitor data subjects’
behavior in the EU, then the non-EU fund manager may be subject to the
GDPR. If the non-EU fund manager has no establishment in the EU, then
the non-EU fund manager may need to appoint an EU representative.
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GDPR: Impact for non-EU fund managers
Non-EU fund managers who are within the scope of the GDPR would have to
meet the full requirements of the GDPR.
– would need to carry out a full GDPR gap analysis/compliance project and
put in place appropriate agreements with respect to any personal data
(including employee and investor data) that the fund manager processes.
– In addition, if any personal data that the non-EU fund manager processes is
transferred outside of the EU (e.g. to the non-EU manager’s home
jurisdiction), then unless that country ensures an adequate level of
protection in relation to the processing of personal data, a mechanism to
transfer that personal data will need to be put in place (such as a data
transfer agreement based on the model clauses).
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GDPR: Impact for non-EU fund managers
Once within the scope of the GDPR, non-EU managers are required to
designate a representative in the EU unless:
– (i) the processing is occasional,
(ii) does not include on a large scale processing of special categories of
data (e.g., health data or race/ethnic data), and
(iii) is unlikely to result in a risk to the rights and freedoms of natural
persons, taking into account the nature, context, scope and purposes
of the processing.
– A non-EU fund manager that has EU investors must determine whether their
processing of investor personal data is merely “occasional”.
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What next steps should a non-EU fund manager be taking
to prepare for GDPR?
A non-EU fund manager should:
– Determine the activities that it carries out either in the EU or in relation to
data subjects in the EU.
– Map the personal data that they collect, store or process in the EU (including
on any servers located in the EU) or in relation to data subjects in the EU,
and determine what it is used for and how long it is kept.
Depending on the activities that the non-EU fund manager carries out and
whether GDPR will apply to its activities, further steps may need to be taken
including:
– Reviewing and updating data protection policies and information security
policies, agreements in relation to the transfer of data, service provider
agreements and employment documentation.
– Review and update fund documentation to the extent necessary.
– Train staff on data protection practices and breach.
– Consider whether an EU representative will need to be appointed.
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Questions?
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Where can I find further information?
Welcome to elexica: www.elexica.com
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on our microsites
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High quality legal and regulatory updates and current awareness alerts
Information on our suite of navigator on-line subscription services including:
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counterparties on a cross-border basis)
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Contact details:
Jonathan Quie
Of Counsel
Financial Markets, Singapore
T +65 6831 5 632
E jonathan.quie@simmons-simmons.com
Jason Valoti
Partner
Financial Markets, Singapore
T +65 6831 5 610
E jason.valoti@simmons-simmons.com
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This document is for general guidance only. It does not contain definitive advice. SIMMONS & SIMMONS and S&S are registered trade marks of Simmons & Simmons LLP. Simmons & Simmons is an international legal practice carried on by Simmons & Simmons LLP and its affiliated practices.
Accordingly, references to Simmons & Simmons mean Simmons & Simmons LLP and the other partnerships and other entities or practices authorised to use the name “Simmons & Simmons” or one or more of those practices as the context requires. The word “partner” refers to a member of
Simmons & Simmons LLP or an employee or consultant with equivalent standing and qualifications or to an individual with equivalent status in one of Simmons & Simmons LLP’s affiliated practices. For further information on the international entities and practices, refer to simmons-
simmons.com/legalresp. Simmons & Simmons LLP is a limited liability partnership registered in England & Wales with number OC352713 and with its registered office at CityPoint, One Ropemaker Street, London EC2Y 9SS. It is authorised and regulated by the Solicitors Regulation Authority.
A list of members and other partners together with their professional qualifications is available for inspection at the above address.
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