2017年-FCA英国金融行为监管局_implementation_of_the_revised_transparency_directive_2页_104kb
报告摘要
Regulator Assessment Summary: Implementation of the Revised Transparency Directive (2013/50/EU)
Core Content
This document outlines the assessment conducted by the Financial Conduct Authority (FCA) regarding the implementation of the revised Transparency Directive (2013/50/EU) in the UK. The directive aims to align the UK's disclosure requirements for investment managers with the EU's minimum thresholds, thereby creating a level playing field for all investment managers across the EU and UK.
Main Points
- Proposal Title: Implementation of the revised Transparency Directive (2013/50/EU)
- Lead Regulator: Financial Conduct Authority (FCA)
- Date of Assessment: 27 September 2016
- Commencement Date: November 2015
- Origin: European Union (EU)
- Cutting Red Tape Review: Not included in the implementation
- Affected Areas: UK Investment Managers
The FCA amended the Disclosure Guidance and Transparency Rules to allow all investment managers to disclose their vote holdings at the EU minimum thresholds (e.g., 5%, 10%, etc.). Previously, UK investment managers and non-EEA managers (excluding the US) were subject to UK super-equivalent thresholds (e.g., 3%, 1% increments thereafter up to 100%). This change reduces the administrative burden on investment managers, as they now only need to notify when crossing EU thresholds, which are higher than the previous UK thresholds.
Key Information
- Level Playing Field: The amendment ensures that all investment managers, regardless of origin, are subject to the same disclosure thresholds, promoting fairness and consistency.
- Administrative Impact: The rule change lessens the administrative burden by requiring notifications at higher thresholds.
- Monetary Impact: The cost of notifications is not significant enough to result in a meaningful monetary impact on the business.
- Estimated Affected Entities: 2,000 UK investment managers are estimated to be affected by the rule change.
- US Investment Managers: Not affected, as they were already subject to the EU thresholds.
Impact Breakdown
| Category | Description |
|---|---|
| Administrative Burden | Reduced due to higher disclosure thresholds (EU) compared to previous UK thresholds. |
| Monetary Impact | Minimal, with the cost of notifications not significant enough to lead to large savings. |
| Cost Savings | Possible savings for investment managers who issue fewer notifications, though overall savings are estimated to be below £50,000 annually. |
| Overall Impact | Negligible, with the monetary impact rounded to zero. |
| Notification Frequency | Previously, investment managers had to notify at lower thresholds, resulting in more frequent notifications. Now, they notify less often, reducing the administrative load. |
Additional Information for BIT Score Validation
- Price Base Year: 2016
- Implementation Date: 2016
- Duration of Policy: 10 years
- Business Net Present Value: £7.3m
- Net Cost to Business (EANDCB): -£0.8m
- BIT Score: -£4.0m
This assessment concludes that the rule change has a negligible impact on the business, primarily due to the low cost of notifications and the fact that many investment managers were already operating under the EU thresholds. The FCA believes that the benefits of a level playing field outweigh the minimal administrative and financial implications.
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