TPR – remember, remember the 9th of December (and the 30th, too)

As we've previously noted, the FCA re-opened its Temporary Permissions Regime (TPR) at the end of September.

The TPR allows EEA firms which have been providing financial services in the UK until now on the basis of passporting rights derived under EU legislation to continue to do business for a period of time after Brexit - so long as they notify the FCA in time that they want to enter the TPR.

There are two deadlines coming up later this month to be aware of:

• by 9 December 2020: fund managers must have notified the FCA (by emailing recognisedcis@fca.org.uk)  if they want to update a TPR notification which has previously been submitted. They should then be ready to submit their updated notification between 14 December and 30 December 2020; and

• on 30 December 2020: the FCA notification window closes - EEA firms and fund managers who haven't already done so should notify the FCA via Connect, that they want to make use of the TPR.

For more information on the TPR, including the details of how it operates, see our earlier update from 2018 here. Note that the term 'no Brexit' or 'hard Brexit' now means should a trade agreement not be reached before 31 December 2020 - but the overall principles of how and when the TPR would be used remain the same.