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You, Me, and the FSAP. Angela Knight Association of Private Client Investment Managers & Stockbrokers. APCIMS statistics. 217 member firms operating on more than 500 sites £280bn under management for the private investor
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You, Me, and the FSAP Angela Knight Association of Private Client Investment Managers & Stockbrokers
APCIMS statistics • 217 member firms operating on more than 500 sites • £280bn under management for the private investor • Last year our members undertook 18.4 million trades in equities, collectives, alternatives and CFDs
The British Government, the Financial Services Authority, the Stock Exchange, Euroclear Crest, the European Parliament, the European Commission, CESR, the Committee of European Securities Regulators, the Bank of England, the European Central Bank The authorities
The FSAP is the Financial Services Action Plan - the forty-two measures and Directives designed to bring about a single market in financial services across Europe FSAP - the content
FSAP - the lamfalussy process • High level principles in the Directive • Technical measures from CESR • Home state regulators to apply • Enforcement
The first two directives • Market abuse • The prospectus directive
MiFID - the big one • MiFID firms include: • All stockbrokers • All investment managers • All wealth management firms • All firms that give financial advice
If there is more and more detail within these Directives then that will mean that firms will operate more and more in the same way. But that means firms will not be able to give the necessary choice to our clients that they do at the moment Harmonisation versus choice
Some specific MiFID changes • Client classification • Best execution • An "appropriateness" test for execution only clients • Portfolio valuations • Record keeping
The Commission has sensibly removed someof the CESR detail The next question is will this pragmatic approach last? The new commission approach
Capital requirements directive (CRD) - The original categories • 50k • 125k • 730k • Banks Investment Also an investment firm, but really an investment bank
Capital requirements directive (CRD) -the new categories • 50k • 125k • 730k lower • 730k restricted • 730k full • Banks Investment firms also an investment firm, but really an investment bank
The new EU view on regulation The deregulation agenda with cost benefit analyses or impact studies is now the way forward
The 'no' vote on the European constitution by France and the Netherlands has in fact been a huge surprise to politicians in the EU The constitution consequence
There is nothing quite like the UK for hanging multiple additional requirements around a European directive, which you in other countries do not do! The UK 'gold plating'
What makes an unattractive financial centre • A financial centre that is too lightly regulated is unattractive • But • A financial centre that is too heavily regulated can also be unattractive
If the pragmatists win there is a good chance of creating a single market at least for wholesale and maybe more If the harmonisers win out, the risk is that the single market becomes much more costly and acts as a business constant
Paramount - the international agenda • Europe / US relations • Europe / China relations