Financial Services SpeedRead: 4 August 2023 edition

Welcome to the latest edition of the Financial Services SpeedRead, a collection of bite-sized updates designed to help you keep on top of key regulatory developments in financial services over the preceding fortnight. Please get in touch if you want to explore any of the topics covered in this fortnight's edition of Financial Services SpeedRead in more detail.

Financial Markets

1. PRA/FCA: Consultation Paper: Margin requirements for non-centrally cleared derivatives: Amendments to BTS 2016/2251 (CP13/23)

On 18 July 2023, the PRA and FCA published a Consultation Paper titled "Margin requirements for non-centrally cleared derivatives: Amendment to BTS 2016/2251".

The Consultation contains proposals to:

• extend the temporary exemption for single-stock equity options and index options from the UK bilateral margining requirements until 4 January 2026; and
• pre-approving bilateral initial margin models.

The proposals apply to:

• PRA-authorised firms that are financial counterparties for the purposes of Article 2 of UK EMIR; and
• all FCA solo-regulated entities and non-financial counterparties in scope of the UK EMIR margin requirements.

The Consultation closes on 18 October 2023.

2. European Commission: Extension of the transition period for third country benchmarks

On 14 July 2023, the European Commission adopted a Delegated Regulation extending the transition period for third country benchmarks to 31 December 2025. The Commission has also published a report on the workings of the existing regime.

The third country-regime under the Benchmark Regulation was supposed to apply from the beginning of 2024. However, the Commission found that a majority of third country benchmark administrators are unprepared for the end of the transition period. The Commission concluded that this would have negative effects on the EU market participants, who would no longer be able to access benchmarks and put such participants at a disadvantage. The Commission hopes that the extension will provide legal certainty and business continuity whilst the Commission works towards a more long-term solution.

3. ESMA: Public Statement on the risks of securities lending in relation to retail clients

On 12 July 2023, ESMA published a statement highlighting the risks of securities lending in relation to retail clients, detailing:

• the key retail investor protection concerns in relation to securities financing transactions (SFTs);
• the relevance of certain applicable MiFID investor protection requirements; and
• relevant practices relating to SFTs in order to illustrate ESMA expectations on the practical applications of the aforementioned requirements.

In relation to its expectations concerning the practical application of MiFID investor protection requirements, ESMA notes the following:

• revenues from securities lending should directly accrue to the retail client, net of a normal compensation for the firm's services; and
• firms should not seek to gain express prior consent from retail clients through acceptance of a firm's general terms and conditions.

4. ESMA: Supervisory briefing on understanding the definition of 'advice' under MiFID (ESMA35-43-3861)

On 11 July 2023, ESMA published a supervisory briefing on understanding the definition of 'advice' under MiFID. The briefing was based on the Q&A on understanding the definition of advice under MiFID published in April 2010 by ESMA's predecessor, CESR.

The briefing covers the following key points:

• whether the provision of personal recommendations and whether other forms of presenting information such as 'investment research', filtering, general recommendations, generic advice, presenting multiple products or access to model investment portfolios could constitute investment advice;
• the presentation of a recommendation as suitable for a client or based on the client’s circumstances, including making recommendations to become a client of a particular firm, making recommendations which are clearly unsuitable in light of knowledge about the client, definitions of a 'person’s circumstances' and when recommendations will be viewed as based on a view of a person’s circumstances;
• perimeter issues around the definition of personal recommendation, including disclaimers to the client and failing to use known client information in an attempt to try avoiding the qualification as investment advice; and
• the form of communication used, including whether the internet or apps are always a 'distribution channel', use of social media posts, messages to multiple clients, distinguishing corporate finance and investment advice and whether these are mutually exclusive.

The full supervisory briefing is available here.

5. HM Treasury: Edinburgh Reforms Update

On 10 July 2023, UK Chancellor of the Exchequer, Jeremy Hunt, gave a speech at Mansion House in relation to the UK financial services regulatory framework. The Government also provided an update to a series of measures it published in December 2022 concerning the post-Brexit UK financial services regulatory framework (the Edinburgh Reforms).

For more information, see our briefing here.

6. Financial Services and Markets Act 2023

On 7 July 2023, the Financial Services and Markets Act 2023 was published following Royal Assent on 27 June 2023. The Act is a significant piece of post-Brexit legislation and provides a framework for revoking retained EU law and replacing it with UK-specific legislation. It was introduced as a Bill in July 2022. Among other things, the Act:

• introduces a designated activities regime (relating to UK financial markets, exchanges, instruments and products) into the financial services regulatory framework to co-exist with the existing framework for regulated activities in FSMA 2000 and the RAO 2001;
• makes amendments to UK MiFID (including the removal of the share trading obligation, aligning the UK derivatives obligation with the UK clearing obligation and conferring powers onto the FCA in respect of pre-trade transparency waivers);
• introduces a gateway through which firms seeking to authorise the financial promotions of unauthorised firms must pass through;
• introduces a regime in respect of critical third parties; and
• brings stablecoins used as payments and other cryptoassets into the UK regulatory perimeter.

The Act will have a staggered implementation, with some provisions having come into force on 27 June 2023 and 11 July 2023, while others will come into force on 29 August 2023 and in 2024 (and beyond).

7. FCA: Consultation Paper: The Framework for a UK Consolidated Tape (CP23/15)

On 5 July 2023, the FCA published a Consultation Paper setting out the framework in respect of a consolidated tape for bonds in the UK (CP23/15). A consolidated tape aims to provide a holistic view of transactions in a specific asset class by collecting market data, such as price and volume associated with trades in financial market.

The Consultation follows the publication of the Wholesale Markets Review in which the Government confirmed plans to introduce a consolidated tape for the UK and forms part of a wider strategy on market data. The Financial Services and Markets Act 2023 gives the FCA rulemaking powers to create a regulatory framework in respect of a consolidated tape in bonds. The FCA is seeking to appoint a single consolidated tape provider (CTP) for bonds, and the Consultation sets out the proposed framework, the FCA's criteria for how a CTP would work, and the tender process for appointing a CTP.

The Consultation also includes a section on a consolidated tape for equities, although the FCA notes that its thinking is less developed in this area but expects a framework to be introduced once the framework for bonds has been established. The FCA also issued a report in respect of the economic model for the UK consolidated tape framework prepared by DotEcon, an external consultancy.
The deadline for comments is 15 September 2023, and the FCA hopes to publish its Policy Statement in December 2023. The FCA hopes to prepare a request for tender document for a UK CTP in 2024.

8. FCA: Policy Statement: Guidance on the trading venue perimeter (PS23/11)

On 5 July 2023 the FCA published a Policy Statement (PS23/11) setting out finalised guidance on when firms may be operating a multilateral system and so require authorisation as a trading venue. This follows a Consultation Paper (CP 22/18) in which the FCA sought views on the meaning of a multilateral system and how it relates to different types of arrangements including:

• technology providers;
• voice brokers;
• portfolio managers operating internal matching systems;
• systems operated for the sole purpose of executing trades on regulated trading venues;
• crowdfunding platforms; and
• bulletin boards.

Q&As 7, 10, 11 and 12 in Section 5 of the ESMA Q&As on MiFID II and MiFIR Market Structures Topics will no longer form part of FCA's supervisory expectations, as these have now been superseded in domestic guidance.

The final guidance is contained in the Perimeter Guidance (Trading Venues) Instrument 2023 (FCA 2023/25) and enters into force on 9 October 2023.

The FCA advises firms to ensure that they have the correct regulatory permissions ahead of the date. The FCA comments that technology providers should still consider the application of the regulated activities regime (e.g. Article 25 of the RAO) to their operations even where they do need authorisation as a trading venue.

9. FCA: Wholesale markets pre-application support service

On 5 July 2023, the FCA announced the launch of its new UK wholesale markets pre-application support service (PASS). PASS has been set up to enable the FCA to provide extra support to firms before they apply for authorisation (including pre-application meetings).

PASS is aimed at:

• overseas firms seeking to set up or expand business in the UK (either with a subsidiary or using a branch);
• firms planning to set up business in the devolved nations or outside the south-east;
• firms with an innovative or unusual business model;
• firms involved in complex or high-risk activities; and
• wholesale service providers.

The FCA also published a new webpage for wholesale market firm applicants on the authorisation process.

Banking and Prudential 

10. PRA: Consultation Paper: Pillar 3 Remuneration Disclosure (CP 14/23)

On 19 July 2023, the PRA issued a Consultation Paper on Pillar 3 Disclosure Requirements (CP14/23). This contains proposals to reduce the number of remuneration disclosures required for smaller banks and building societies, and follows on from the PRA's February 2023 consultations CP4/23 (containing proposals to introduce disclosure requirements for so-called simpler-regime firms) and CP5/23 (containing proposals on amending the definition of small CRR firm and small third-country CRR firm for remuneration purposes).

The PRA confirms that its remuneration requirements will apply to:

• firms that satisfy the simpler-regime criteria described in CP4/23;
• other small CRR firms described in CP5/23; and
• small and non-complex institution (SNCI) firms that will not be simpler-regime Firms, but that will be eligible to become small CRR firms (SNCI transitional firms).

The deadline for responses is 20 September 2023. The PRA plans to publish the final policy on remuneration disclosures as part of its Strong and Simple framework in Q4 2023.

Financial Crime

11. ESMA: Report on Suspicious Transaction and Order Reports (STORs)

On 14 July 2023, ESMA published a report on Suspicious Transaction and Order Reports (STORs). The report covers the period of 2021/2022 and considers:

• the number of STORs and other notifications received by national competent authorities;
• the source of the notifications;
• the breakdown per instrument type and type of violation; and
• the number of STORs provided to and received from other Competent Authorities (both within and outside the EEA).

12. EBA: Opinion on money laundering and terrorist financing risks affecting the EU's financial sector

On 13 July 2023, the EBA published its fourth biennial Opinion on the risks of money laundering and terrorist financing affecting the EU's financial sector. The Opinion also contains information on what can be done by the competent authorities and EU co-legislators to mitigate those risks.

Some AML/CTF risks had been identified in previous EBA Opinions, such as those associated with cryptoassets and innovative financial services. Other risks are deemed to be decreasing, such as those associated with Covid-19.

Other key points to note from the Opinion include:

• awareness of AML/CTF risks is increasing across all sectors under the EBA's AML/CFT remit. However, the systems and controls that institutions have put in place are not always effective, particularly in relation to approaches to transaction monitoring and reporting of suspicious transactions;
• AML/CFT supervision is improving overall. However, AML/CFT supervision is not always commensurate to perceived levels of AML/CTF risk or effective overall; and
• co-operation of AML/CFT supervisors with other authorities has improved as a result of EBA initiatives. However, this co-operation can be further improved with tax authorities for tax-related crimes.

Retail Services

13. FCA: Guidance Consultation: Financial promotions on social media (GC 23/2)

On 17 July 2023, the FCA published a Guidance Consultation on how financial promotion requirements apply to promotions on social media. The stated aim is to modernise the information firms use when making and approving financial promotions online. To prevent consumer harm, the FCA wants the guidance to be reflective of how social media is being used. The FCA has been keen to respond to an increased trend of "finfluencers" making illegal financial promotions (see the April 26 2023 edition of the FSS here).

The guidance consultation is in light of the Consumer Duty which increases expectations on firms who make or authorise financial promotions and is line with the FCA's 2023/2024 Business Plan strategy to reduce and prevent serious harm and to set and test higher standards.

The consultation closes on 11 September 2023.

You can read the FCA's press release here.

14. HM Treasury: Response to consultation on UK retail disclosure

On 11 July 2023, HM Treasury published the response to its December 2022 Consultation on a proposed alternative disclosure framework for UK retail disclosures.

In the response, the Government confirms it plans to repeal retail disclosure requirements in the UK PRIIPs Regulation, so the FCA can deliver a new UK retail disclosure regime tailored to the UK market.

In response to feedback received, the Government confirms it will ensure that the FCA considers concerns raised in relation to:

• products in scope of the new UK disclosure regime;
• accuracy of disclosure information; and
• balancing flexibility with comparability.

In relation to other aspects of the future regime, the Government also confirms that it will:

• provide further detail in relation to FCA's powers over certain unauthorised firms (obligations these firms are subject to will be removed upon the repeal of UK PRIIPs) and overseas funds (to address concerns about maintaining a level playing field for UK funds and appropriate information for UK retail customers); and
• consider feedback provided on MIFID costs and charges disclosures.

The Government intends to publish a draft Statutory Instrument by 2024 , to enable the FCA to introduce the new retail disclosure regime. The FCA is expected to publish a Consultation Paper seeking draft rules for the new retail disclosure regime in due course.

Asset Management

15. European Parliament and Council: Provisional agreement on 'AIFMD II' reached

On 20 July 2023, the Council of EU and the European Parliament announced that a provisional agreement had been reached in respect of the legislative proposal updating AIFMD. The legislative proposal was introduced in November 2021 by the European Commission, and has been making its way through the EU legislative process (see our briefing here).

Notable aspects of the provisional agreement highlighted include measures to:

• enhance the availability of liquidity management tools;
• enhance rules for delegation by investment managers to third parties;
• enhance data sharing and co-operation between authorities; and
• identify undue costs that could be charged to funds.

The provisional agreement must be confirmed by the European co-legislators before it can be formally adopted.

16. European Commission: Report on MMF Regulation adopted

On 20 July 2023, the European Commission adopted a report in respect of the EU Money Market Funds Regulation (MMF Regulation).

The report looks at key changes introduced by the MMF Regulation, market structure and recent market developments, and considers the MMF Regulation from a prudential and economic perspective.

The report concludes that recent events (such as COVID-19 related market turmoil) indicate that safeguards in the MMF Regulation have been working as planned. However, the report cites areas for improvement in the regulatory framework, including the resilience of EU MMFs and structural problems that are external to MMFs. The report argues that harmonised rules to increase the availability of liquidity management tools contained in the 2021 AIFMD legislative proposal should go some way in addressing concerns about the resilience of liquidity management of EU MMFs.

The European Commission confirmed that it will not propose a revision to the MMF Regulation.

17. FCA: Multi-Firm Review and Dear CEO Letter: Liquidity Management

On 7 July 2023, the FCA published the detailed findings and good practice from its multi-firm review of liquidity management frameworks. In connection with this, the FCA has also written to the sector in a companion Dear CEO Letter. This follows the FCA's letter to the Boards of Authorised Fund Managers (AFMs) in November 2019, detailing good practice in liquidity management.

The FCA asked a sample of 14 firms of different sizes to provide information on their liquidity management frameworks and followed up with in-depth discussions on their methodologies.

Key findings of the review include:

• tools for effective liquidity management were usually in place at firms, but these lacked coherence when viewed holistically and were not always embedded into daily activities;
• many firms place insufficient importance on liquidity risk management in their governance oversight arrangements, as well as insufficient challenge and escalation;
• there are a wide range of approaches to liquidity stress testing adopted by AFMs, with some methodologies insufficient to assess actual liquidity of the portfolio, using assumptions that were not appropriately conservative;
• firms usually had governance and organisational arrangements in place to meet large one-off redemptions but did not have adequate arrangements in place to oversee cumulative or market-wide redemptions that could have a significant impact on a fund; and
• divergences in the application of anti-dilution tools such as swing pricing, which could affect the price investors receive when redeeming.

The FCA expects all UK AFMs and AIFMs to consider the findings for their businesses. In particular, the FCA stated that the examples of good practice set out in the review and the Dear CEO Letter contribute to improved consumer outcomes consistent with the Consumer Duty, which comes into force on 31 July.

18. ESMA: Report: Marketing requirements and marketing communications under the Cross-Border Distribution of Funds Regulation

On 3 July 2023, ESMA published a Report on national rules governing the marketing of investment funds under the Cross-Border Distribution of Funds Regulation.

The Report sets out ESMA's overview of the marketing requirements across Member States, and analyses the effects of national laws, regulations and administrative provisions implementing such requirements.

Key findings from the report include:

• in ESMA's view, the transposition of the Cross-Border Distribution of Funds Directive and the ESMA Guidelines on fund marketing communications have increased harmonisation across member states in areas where national divergences existed; and
• despite the powers NCAs have under the Regulation, only a limited number of NCAs carry out any ex-ante verifications of marketing communications, while an increasing number of NCAs reported carrying out ex-post verifications.

ESMA will submit a new version of the report in two years' time.

Payments

19. HM Treasury: Policy Statement on payment account contract termination and freedom of expression

On 21 July 2023, HM Treasury published a Policy Statement on Payment Account Contract Termination and Freedom of Expression. This follows HM Treasury's January 2023 Call for Evidence on the Payment Services Regulations 2017 (PSRs), in which it sought views on the workings of the existing regulatory regime. In particular, the Call for Evidence sought views on the effectiveness and fairness of Regulations 51 and 71 in the PSRs in light of recent concerns raised about high-profiles cases involving the closure of payment accounts.

The Policy Statement confirms there will be amendments to the payment services regulatory framework applicable to customers' payment accounts that will involve:

• requiring that a clear and tailored explanatory reason must be given to a customer when their payment account has been terminated, unless to give such reason would be unlawful; and
• requiring that payment account providers provide at least 90 days’ notice when choosing to terminate a contract, unless for a serious and uncorrected breach (such as non-payment) or other serious occurrence, and clarification that clauses in user agreements allowing termination for other matters (such as brand protection) cannot be used to get around this.

The Government also states that a consumer being a domestic politically exposed person under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 is not a valid reason for firms refusing to provide banking services in the absence of other risk factors.

The Policy Statement does not represent the full, formal response to the Call for Evidence, which is expected later in 2023.

20. HM Treasury: Call for input and terms of reference on Future of Payments Review 2023

On 11 July 2023, the Government issued a call for input in relation to the Future of Payments Review 2023, alongside terms of reference. The Review be focused on the consumer perspective (in this sense both individuals and businesses making and receiving retail payments) and is primarily seeking views on the following areas:

• the most important consumer retail payment journeys both today and in the next 5 years;
• how the UK consumer experience for individuals and businesses compares to other leading economies; and
• the likelihood of in-flight plans and initiatives across the payments landscape delivering world leading payment journeys for UK consumer.

The Review is expected to consider how the UK’s retail payment systems and networks need to adapt to engender innovation in payment services, serve the future retail payments needs of businesses and consumers (the Review is not considering RTGS and CHAPS systems used for wholesale payments) and new forms of digital money.

The deadline for comments is 11 September 2023.

21. European Commission: Legislative proposals in relation to the EU payment services regulatory framework

On 5 July 2023, the European Commission and Council published a suite of proposals for a revised payment services and e-money regime. The changes represent an evolution of the current regime, with the implementation of a new PSD3 and Payment Services Regulation (PSR) to replace the incumbent PSD2 and EMD2. Accordingly, electronic money institutions (EMI) and payment institutions (PI) will be consolidated to be supervised and authorised under a single regime. Firms operating under this regime will be required to apply for re-authorisation with their existing operations grandfathered into the regime for a period of 30 months.

Under proposed changes, an open finance framework will be contained in the Financial Data Access Regulation (FIDA). Financial institutions will be required to share client data upon request by another financial institution subject to client consent. The proposed changes will streamline data sharing between institutions.

For further details on the proposed changes, please see our briefing here.

Digital Services and Fintech

22. EBA: Statement encouraging timely preparatory steps towards the application of MiCAR to asset-referenced and e-money tokens

On 12 July 2023, the EBA published a Statement addressed to financial institutions and other entities who intend to commence asset referenced token (ART) or electronic money token (EMT) activities prior to 30 June 2024. The Statement emphasises the need for timely preparation for the MiCAR application in order to prevent any risks of disruptive or sharp business model changes for customers.

The statement sets out the following guiding principles to be adhered to if carrying out ART/EMT activities:

• disclosures to, and fair treatment of, potential acquirers and holders of ARTs and EMTs;
• sound governance, including effective risk management;
• reserve, recovery and redemption arrangements; and
• communications with the relevant competent authority.

The EBA also warns consumers that ARTs and EMTs do not yet constitute regulated instruments and that the consumer protection provisions under MiCAR are not applicable before 30 June 2024.

23. FCA: Speech by Nikhil Rathi, Chief Executive: The FCA's emerging regulatory approach to AI and Big Tech

On 12 July 2023, the FCA published a copy of a speech delivered at The Economist by Nikhil Rathi, the Chief Executive of the FCA, in relation to the emerging regulatory approach of the FCA towards Big Tech and AI. Key points in the speech included:

• the gatekeeping of financial data will come under increasing scrutiny with clear risks to the operational resilience of existing payments, retail services and financial infrastructure, and monopolisation of key data poses a risk to the manipulation of consumer behavioural biases;
• the use of AI can have a volatile impact on markets impacting integrity, price discovery and transparency, and generative AI poses the risk of affecting confidence in the market as well as impacting the market through false stories or AI-led cyber fraud, therefore clear checks and balances on such technology would be required;
• the FCA recognises the benefits of generative AI, and as a data-led regulator is preparing to monitor such technology through developing, and purchasing when necessary, supervisory technology that has the ability to scan the tech horizon and identify relevant AI technology;
• the FCA's current outcomes and principles-based approach to regulation, such as SMCR and Consumer Duty, continue to relevant to firm's considerations of ensuring consumer protection and market integrity as firms implement AI.

24. FCA: Feedback Statement: The potential competition impacts of Big Tech entry and expansion in retail financial services (FS23/4)

On 12 July 2023, the FCA published a statement summarising feedback received following Discussion Paper (DP22/5), intended to start discussion on the impacts of Big Tech entry into financial services, and to identify areas of benefit and risk. The FCA received feedback from a range of stakeholders, setting out the following key themes for discussion:

• differing Big Tech business models and strategies;
• refining the FCA's analytical framework;
• data access and data sharing;
• Big Tech activity at, or beyond, the FCA's regulatory perimeter; and
• overlaps with regulators and other regimes.

In line with the holistic strategy of the FCA, including commitments to open banking and development of regulatory frameworks towards Critical Third Parties and AI, the FCA has proposed the following additional steps in response to the feedback received:

• launch, by the end of 2023, a Call for Input on Big Tech firms as gatekeepers, and key drivers including the role of data sharing asymmetry between Big Tech firms and financial services;
• review its supervisory approach for Big Tech firms;
• continue to work with the Digital Markets Unit (DMU) as the new Digital Markets, Competition and Consumers Bill passes through Parliament; and
• at the appropriate time, set out the detail of how to implement the regulatory coordination provisions in the Bill through a memorandum of understanding with the DMU.

25. MiCAR: Consultation Papers by ESMA and EBA on first sets of ITS and RTS

On 12 July 2023, ESMA issued a Consultation Paper containing draft regulatory technical standards and implementing standards under MiCAR in relation to cryptoasset service providers (CASPs).

Areas covered by the draft RTS include notification of intention to provide cryptoasset services and authorisation of CASPs. The draft ITS cover standard forms, templates and procedures in respect of a notification of intention to provide cryptoasset services and in respect of the authorisation of CASPs.

The deadline for comments is 20 September 2023 and ESMA plans to publish a final report and submit the draft RTS and ITS to the European Commission for endorsement by 30 June 2024.

On the same day, the EBA issued Consultation Papers on MiCAR, covering:

• draft technical standards and implementing technical standards in relation to the application for authorisation of issuers of asset-referenced tokens under MiCAR;
• draft technical standards on complaints handling procedures for issuers of asset referenced tokens under Article 31 of MiCAR; and
• draft technical standards in relation to notifications concerning acquisitions and increase of qualifying holdings in issuers of asset referenced tokens.

The deadline for comments to the Consultation is 12 October 2023.

26. FCA: Cryptoasset firms marketing to UK consumers must get ready for the financial promotions regime by 8 October 2023

On 4 July 2023, the FCA published a letter from Lucy Castledine, Director of Consumer Investments Supervision, Policy and Competition, urging in-scope firms (i.e. all firms marketing cryptoassets to UK consumers, including firms based overseas) to get ready for the new financial promotions regime for cryptoassets.

The letter notes that once the regime comes into force, there will only be four routes to lawfully communicate cryptoasset promotions to UK consumers, and that persons illegally promoting to UK consumers could be placed on the FCA warning list.

Unregistered or unauthorised cryptoasset businesses marketing to UK consumers are advised to consider:

• which of the four legal routes they will use to make their financial promotions;
• how they will deal with UK customers if they are unable to communicate financial promotions to them; and
• have in place orderly wind downs if they can no longer provide services to UK clients.

Cryptoasset firms seeking registration under the MLRs are reminded of the FCA's expectations in this area, and that poor quality/incomplete submissions will be rejected.

Other

27. FCA: New Webpages: Appointed Representatives and Regulatory Hosting

On 11 July 2023, the FCA published the following new webpages:

• regulatory hosting services, setting out the information relevant to principal firms operating as regulatory hosts; and
• how to report Appointed Representatives data (information for principal firms), setting out the data that principal firms must report to the FCA about their Appointed Representatives.

The new webpages are accessible here and here.