Author:Keller Albertson

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Europe: UK FCA Plans to Streamline UK Sustainability Reporting
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Europe: UK Consultations on Reducing the Burden of the FCA Senior Managers Regime
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Europe: Fundamental Reform of UK Taxation of Carried Interest
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Europe: Central Bank of Ireland Updates its UCITS Q&A on Portfolio Transparency for ETFs
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United States: SEC Appears Poised to Bolster Competition on “Y’all Street”
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Europe: UK’s FCA Intensifies Scrutiny on Private Markets Valuations
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Europe: UK’s FCA Seeks to Simplify Its Rules
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United States: Trust But Verify (With A Minimum Investment Amount)
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Europe: National Regulators Announce Digital Operational Resilience Act Reporting Windows
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Middle East: New Saudi Netting Regulation Creating a Buzz

Europe: UK FCA Plans to Streamline UK Sustainability Reporting

By: Kai Zhang and Andrew Massey

Following a multi-firm review of sustainability reporting, the FCA has announced that it is considering how to streamline and enhance the UK’s sustainability reporting framework by simplifying disclosures, easing unnecessary compliance burdens, improving the decision-usefulness of reporting and promoting international alignment.

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Europe: UK Consultations on Reducing the Burden of the FCA Senior Managers Regime

By: Zainab Kuku, Philip Morgan, and Andrew Massey

As part of the UK government’s strategy to boost the competitiveness of the UK financial services sector and support growth, the overall burdens of the Senior Managers & Certification Regime (SMCR) are to be reduced “by 50%”.

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Europe: Fundamental Reform of UK Taxation of Carried Interest

By: Giles Bavister, Ayesha Gill, and Neil Woodgate

From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was published by HMRC in July 2025.

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Europe: Central Bank of Ireland Updates its UCITS Q&A on Portfolio Transparency for ETFs

By: Lucy Deane, Hazel Doyle, and Nicola McCaffrey

In a move that will be welcomed by asset managers conducting ETF business in Ireland, or those who are hoping to move into the Irish ETF space, the Central Bank of Ireland has moved to allow for the establishment of semi-transparent ETFs by amending its requirements for portfolio transparency.

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United States: SEC Appears Poised to Bolster Competition on “Y’all Street”

By: Jessica Cohn and Caroline Roethlisberger

On 4 April 2025, the Securities and Exchange Commission (SEC) published Texas Stock Exchange’s (TXSE) Form 1 Application and Exhibits, indicating that the SEC intends to grant TXSE’s registration as a national securities exchange. The application provides new details about TXSE, including its proposed listing standards and requirements and the technology to be utilized. TXSE has previously announced that it expects to receive that necessary SEC approval and be listing companies and funds on its exchange by early 2026.

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Europe: UK’s FCA Intensifies Scrutiny on Private Markets Valuations

By: Daniel Greenaway and Flavio Picaro

The UK’s Financial Conduct Authority has published the findings of its multi-firm review of valuation processes for private market assets. This review follows the highlighting of vulnerabilities in private markets stemming, in part, from opaque valuations, in both the Bank of England’s June 2024 Financial Stability Report and IOSCO’s September 2023 report on emerging risks in private finance markets.

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Europe: UK’s FCA Seeks to Simplify Its Rules

By: Laura Price and Kai Zhang

Acknowledging “longstanding concerns from firms about the length and complexity of [its] rules and guidance”, the UK’s FCA published a call for input in July 2024. It invited firms to comment on whether some FCA rules may be unnecessary following introduction of the outcomes-based Consumer Duty. It has now outlined its proposed approach in a Feedback Statement, explaining that its aims are to achieve more flexibility, more predictability, and improved efficiency. The approach includes:

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United States: Trust But Verify (With A Minimum Investment Amount)

By: Pablo Man and Ruth Delaney

On 12 March 2025, the SEC staff issued a no-action letter for offerings under Rule 506(c) of Regulation D. In the letter, the Staff concurs that an issuer will have taken “reasonable steps to verify” a purchaser’s accredited investor status in an offering conducted under Rule 506(c) if the issuer requires purchasers to agree to certain minimum investment amounts, subject to a few additional conditions:

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Europe: National Regulators Announce Digital Operational Resilience Act Reporting Windows

By: Shane Geraghty, Dr. Ulrike Elteste, and Ruth Hennessy

EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as 31 March 2025. ROIs are reports by in-scope EU financial entities on all contractual arrangements on the use of information and communication technology (ICT) services provided by ICT third-party service providers. The financial entity must differentiate between providers who are not critical and providers who are considered critical and important.

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Middle East: New Saudi Netting Regulation Creating a Buzz

By: Ron Feldman and Amjad Hussain

There was a buzz during the joint association conference in Riyadh, Saudi Arabia on the 19 February. A collaboration by ISDA, ISLA and ICMA, the industry associations representing parties that enter into transactions such as derivatives, securities lending and repurchase transactions, is indeed unusual.

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