UK MiFID quick fix – practical implications for investment managers

The UK MiFID quick fix

As part of a post-Brexit process of addressing key concerns around the efficacy of the UK MiFID regime (known as the MiFID quick fix), the UK Government and FCA have recently made de-regulatory changes to the conduct of business rules in the UK.

Many of the changes made have a direct practical impact on UK investment managers, and offer a useful opportunity for UK firms to simplify their regulatory obligations:

• Certain changes came into force in H2 2021, including reduced client-reporting requirements for portfolio management services, and the scrapping of the “Top 5” reports under the best execution rules.
• More recently, new changes the UK inducements rules came into force this month (March 2022), including an important expansion in the list of acceptable minor non-monetary benefits, which an investment manager can receive for free or on a bundled basis. This includes research on certain SMEs, FICC research, and research from independent research providers.

Simmons client note

Our client note summarises the key practical impacts of these conduct rule changes for UK investment managers, including certain internal and external reporting processes which firms may need to update, and additional flexibility in the inducements rules and consumption of research.

It also sets out details of a patch notification that we’ve drafted, which firms may wish to adopt - this will assist investment managers with updating their client-facing disclosures.

UK investment managers should check that they’ve addressed all the recent changes, and then take appropriate action if any changes still need to be implemented.

Other Simmons resources

For more information on MiFID3 generally, please see our MiFID3 View .