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Unravelling the options and next steps for marketing funds into the UK post Exit Day

  • United Kingdom
  • Financial services and markets regulation
  • Financial institutions


Our client briefing on 7 January 2019 provided details on the temporary permissions regime (“TPR”) and included flowcharts for both firms and funds to help navigate the regime, while our briefing on 16 January 2019 looked at some key practical considerations to help make the process as simple as possible, as well as the contents of the TPR notification forms.

Following feedback from clients, we have now prepared a further flowchart to help unravel the options, next steps, requirements and processes for the marketing of funds into the UK after Exit Day.

Our new flowchart on marketing of funds into the UK after Exit Day sets out the various considerations in respect of the following:

  • Funds within TPR – wishing to opt out of the regime or continue marketing in the UK
  • Funds that did not apply for TPR prior to Exit Day – wishing to recommence marketing of these funds or market new funds in the UK
  • Funds exempt from TPR – although fund managers can generally continue to market in the UK as prior to Exit Day, Gibraltar-based firms need to be aware that a new framework is expected

Click here to download the flowchart >

How Eversheds Sutherland can help

Since June 2016, our lawyers, consultants and International Funds Net (IFN) team have advised various institutions passporting into the UK from EU27 Member States and passporting from the UK into the EU27 on Brexit planning and Brexit related issues.

We would be happy to discuss how we can help you with your Brexit planning and execution of those plans, including assisting you with changes and TPR notifications. Eversheds Sutherland are able to be registered as an additional user by clients on the Connect system to assist with notifications on a fixed fee basis.