MFA Letter on UK Implementation of Investment Firm Directive and Regulation

On September 25, MFA submitted comments to the UK Financial Conduct Authority in response to its discussion paper on implementing the EU’s Investment Firm Directive and Regulation. In the letter, we encouraged the FCA to: (1) calculate assts under management in a manner consistent with industry practice, netting positive and negative values; (2) adopt a proportional approach in applying rules to firms of different size, organization, and nature, in particular with respect to remuneration rules; (3) permit firms to calculate their assets based on a monthly average rather than using only year-end balance sheet numbers, which can significantly inflate a manager’s true size; (4) appropriately tailor the rules to avoid an overly broad extraterritorial impact; and (5) ensure that the IFR rules on gender neutrality align with existing UK rules to avoid potential conflicts.