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PIMFA - Building personal financial futures

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PIMFA Fortnightly News Bulletin - 4th December 2019 Welcome to the PIMFA Bulletin, our fortnightly e-newsletter delivering a snapshot of the latest news and current affairs from within PIMFA and the industry.

What is PIMFA working on? New PIMFA Member Firm We are excited to welcome another new member to PIMFA:


Servo Private Wealth – Wealth Manager

We look forward to working with you.

Attention Required: Insurance Distribution Directive (IDD) update on Professional Indemnity Insurance (PII) cover The Commission’s Regulatory Technical Standards, adopting the base Euro amounts for PII and for financial capacity of insurance and reinsurance intermediaries, was published in the Official Journal of the EU.

The figures have changed as follows: -

the minimum amount of EUR 1 250 000 per claim is increased to EUR 1 300 380 per

claim; -

the minimum amount of EUR 1 850 000 for all claims/year is increased to EUR 1 924

560 for all claims/year; and -

the minimum amount of EUR 18 750 of financial capacity is increased to EUR 19 510.

The Regulation will enter into force on the 12th December 2019 and will apply from the 12 June 2020. This Regulation is binding in its entirety and directly applicable in all EU Member States. The methodology for calculating the above is prescribed in detail by the IDD and there is no discretion on the method for calculating these amounts. Firms do need to be aware that the new adjusted figures may require reconsidering and possibly renegotiating contracts for PII to take the new minimum amounts into account.

For further information, please contact Alexandra Roberts.

PIMFA responds to European Securities and Markets Authority's (ESMA) consultation on the Market Abuse Regulation (MAR) review In our response to the above, PIMFA supports ESMA’s view that the MAR regime should not be extended to spot foreign exchange contracts. To read the full response to ESMA’s consultation on MAR review, please click here.

For further queries, please contact Giulia Lupato.

PIMFA Operational Resilience Working Group The PIMFA Operational Resilience Working Group held its second meeting in November. The group explored an approach to defining critical business services and reviewed their own lists of services. They also looked at the principles of setting impact tolerances and important considerations when running a success end-to-end pilot.

Copies of the meeting notes and presentation slides are available from

If you would be interested in joining this group, please contact

PIMFA Central Securities Depositories Regulation (CSDR) Working Group The PIMFA CSDR Working Group is holding its next meeting on Monday 9 December 10:00 – 11:30 at PIMFA’s office or via the conference call.

If you are interested in attending the meeting and joining the group, or receiving the notes and presentation slides from the meetings, please contact

Sustainable Finance The European Commission published draft delegated regulations for investment firms and insurance distributors amending MiFID II and the IDD to ensure sustainability issues are taken into account when advising clients. Where it is unclear, suitability will remain the priority even if the most suitable recommendation does not completely meet the clients sustainability requirements.

This will require firms to take ESG factors into account in the suitability assessments they undertake. ESMA Guidelines were published in May 2018 and specify it is good practice for firms providing investment advice or portfolio management to collect information on their client’s ESG preferences.

The delegated regulations were published in the Official Journal on 27 November 2019, available here, and the ESMA Guidelines previously issued became applicable. PIMFA's new Useful Guide, "Sustainable Finance - PIMFA's A to Z Guide 2019", is available in the members only area here.

New Venture Capital Trust (VCT) Guide from I ntelligent Partnership Intelligent Partnership has produced "An Adviser's Guide to Venture Capital Trusts" to which a number of professional advisers and trade bodies (including PIMFA) have contributed articles. The Guide outlines the VCT landscape, covers various aspects of investing in these instruments (e.g. risks and rewards, tax reliefs, charges, suitability, research, due diligence) and provides a number of investment case studies.

To view the Guide, please click here.

PIMFA Parliamentary Day 2020 As you may be aware, PIMFA will be taking up residence in Parliament on 23 January 2020 in order to raise the profile of this profession and build lasting relationships with the new intake of MPs following the forthcoming General Election. We are particularly keen to represent the country as a whole. If you would like to get involved in lobbying your local MP, please get in contact at

White-listing the PIMFA domains to ensure all our emails reach you Please ask your IT teams to white-list our domains - and – this will ensure that PIMFA communications are not blocked and that you don’t miss out on your free member benefits such as webinars, podcasts, Update, newsletters, CEO updates, technical useful guides, event invitations and more. If you have any questions, please email us at and we will be happy to help.

Latest PIMFA Press Releases 

PIMFA Responds to Financial Transaction Tax

PIMFA Launches Mental and Financial Wellbeing Campaign

PIMFA Calls for the Regulator to Raise The Bar

Sustainability, Diversity and Wellbeing Highlighted As Key Topics at PIMFA Summit

PIMFA Announces Strategic Partnership with Investor Meet Company

Read all of PIMFA's Press Releases

Latest PIMFA Consultation Responses

PIMFA Consultation Response on ESMA's Market Abuse Regulation Review

PIMFA’s response to Law Commission Intermediated Securities - Call for Evidence

PIMFA response to Pension transfer advice: contingent charging and other proposed changes

PIMFA’s response to Guidance Consultation 19/3: Guidance for firms on the fair treatment of vulnerable customers

ESMA Call for Evidence:Inducements and Costs and Charges: Disclosure Requirements under MiFID II

Read all of PIMFA's Consultation Papers

What's coming up in PIMFA? 2020 Events and Learning Call for Speakers Do you or someone you know have an amazing story to share, a great innovation to showcase or do you just love being on stage? Complete our Call for Speakers Submission form and let us know about it so we can get you involved in 2020!

Please click here to complete your submission

Financial Adviser Forum 22 January 2020, 13:30 – 20:00 Farrer & Co, 20-23 Lincoln’s Inn Fields, London WC2A 3ED Our Forum begins at Farrer & Co with an afternoon of education and CPD, ending the day with a drinks reception at the House of Lords. Topics on the day will include: 

Retirement – How do Financial Planning Build a Client Friendly Proposition for the Future?

Managing Risks in Challenging Economic Environments

Client Communications – How to Drive Better Understanding

The How to Guide to Acquisitions

Later Life Advice – Preparing for Care, IHT, Intergenerational Wealth Transfer

The educational forum will be followed by a drinks reception at the House of Lords.

Sign Up

Financial Crime Conference 4 February 2020, 08:30 – 17:00 Herbert Smith Freehills, London Join us at the PIMFA Financial Crime Conference 2020 and access leading industry debate from professionals across the regulatory, law enforcement and cyber security space. As the financial crime landscape evolves with new techniques and technologies, the growing threat to firms and their clients is undeniable.

Confirmed • • •


Commissioner Alison






include: City



Police –



Catherine Kernaghan, Head of Counter-Illicit Finance & Economic Crime

Reform •


HM Damon




Treasury –


Susannah Cogman, Financial Crime Expert and Partner – Herbert Smith Freehills

Sign Up

Wealth of Diversity Conference & Women in Wealth Drinks 17 March 2020, 08.30 - 19.00 Fidelity International, 4 Cannon St London, EC4M 5TA

Today we face many challenges in recruiting and engaging with our workforce and, with a diverse client base and shifting wealth patterns, the need for diversity and inclusion in our workforce is ever increasing to meet the needs of clients, existing and potential.

Join us to discuss topics including: •

Culture and Inclusion • •


Unconscious Bias Why Diversity Matters

Early Bird tickets available for a limited time, click on the box below to book your place.

Sign Up

What's happening in our industry Latest news from the Financial Conduct Authority FCA consults on how to extend the Senior Managers Regime to benchmark administrators The FCA has published a consultation on how to apply the Senior Managers Regime (SMR) to benchmark administrators.

The SMR sets important standards for governance and accountability, and will apply to almost all FCA-regulated firms from December 2019. As benchmark administrators are a new category of authorised firms they have been granted a one-year extension from the wider roll out of the SMR. The new rules will come into force for these firms on 7 December 2020.

SMR is designed to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence. Benchmark administrators provide critical market infrastructure and the pricing of many financial instruments and contracts depends on the integrity of the benchmarks they administer. As a result, healthy cultures and high standards of personal conduct are important in

preventing harm to markets and consumers.

The Consultation closes on 28th February 2020. To view the Consultation in full, please click here.

MIFID investment firms will need to use a new form to notify FCA of management body changes for Non-Senior Management Function (SMF) Directors From 9 December 2019, MIFID investment firms and optional exempt firms will need to use a new form to submit information to the FCA when appointing Non-SMF Directors to, or withdrawing them from, their management body.

Firms can currently preview the form, and it will be available to download from the Handbook from 9 December 2019. If a firm’s management body changes, they will need to download the form, complete it and email it to the FCA via This is a temporary process. From Q1 2020, firms will be able to submit the form via Connect, the FCA’s online platform. Any firms who don’t currently have access to Connect should prepare by registering now.

For information, FCA consulted on these changes in June 2019 and published their final rules in September 2019.

There is a news story published on the FCA website outlining the above, available here

Latest Industry Events

View all the latest industry events on our website here If your firm has an event which you would like to post on this area, please click here to submit it.

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