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    PRA Updates Permissions Regime Requirements for Third-Country Branches

    September 02, 2020

    The PRA Deputy Governor Sam Woods issued a letter to the chief executive officers of all PRA-regulated firms that are preparing for the end of the Brexit transition period and for entering the Temporary Permissions Regime. The letter informs that PRA has updated its approach to the Temporary Permissions Regime as well as the key requirements for branches. The letter reminds regulated firms that the transition period is due to end at 11 pm on December 31, 2020, when the Temporary Permissions Regime will take immediate effect. It also highlights that the actions needed to be taken to ensure operational preparedness will vary across firms.

    Firms that have submitted a valid Notification or submitted a Part 4A application (and not subsequently withdrawn it) will automatically enter the Temporary Permissions Regime. During the Temporary Permissions Regime, a firm will have a deemed Part 4A permission to carry on its existing activities for up to a maximum of three years from the end of the transition period. If the firm is passporting and already has a top-up permission, a deemed variation of that permission will need to a obtained. Given this, it is important that a firm is operationally prepared to enter the Temporary Permissions Regime and is able to meet the regulatory requirements that will apply once in it. For firms in the Temporary Permissions Regime without a branch in the UK (cross-border service providers) a more limited set of rules will apply. Finally, in the letter, PRA urges the regulated firms to review the published information on the Temporary Permissions Regime and take all appropriate actions to ensure full operational preparedness before entering the Temporary Permissions Regime.


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    Keywords: Europe, UK, Banking, Insurance, Temporary Permissions Regime, Transition Period, Operational Requirements, Brexit, Passporting Regime, Third Country Branches, PRA

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