• On 19 December 2024, the FCA published a consultation paper (CP24/30) on the new product disclosure regime known as the Consumer Composite Investments (CCI) regime. The consultation paper follows the FCA’s discussion paper DP22/6: Future Disclosure Framework in 2022 and the Treasury’s consultation on replacing PRIIPs Regulation and the UCITS disclosure requirements. The FCA plans to issue a policy statement with final rules in 2025.

CP24/30: A new product information framework for Consumer Composite Investments | FCA

• On 13 December 2024, the FCA released a portfolio letter updating the supervision strategy for firms in the custody and fund services sector. The FCA’s supervisory priorities included operational resilience; cyber resilience; third party management; change management; market integrity; depositary oversight and protection of client assets.

Portfolio letter: Custody and fund services supervision strategy

• On 12 December 2024, the FCA published a consultation paper (CP24/27), setting out the FCA’s high-level proposals for a new model of investment advice in relation to pensions known as targeted support. These proposals are the first stage of reforms within the framework of the FCA’s advice guidance boundary review. Firms have until 13 February 2025 to respond to the consultation. 
  
  Alongside CP24/27, the FCA also published a discussion paper on certain other aspects of the pensions regulatory framework that may require reform (DP24/3). The discussion paper focuses on the regulatory regime that governs projections and digital tools and modellers, requirements for defined contribution pension transfers and consolidation; and the regulations surrounding self-invested personal pensions. The deadline for response to DP24/3 is 27 February 2025.

CP24/27: Advice Guidance Boundary Review – proposed targeted support reforms for pensions

DP24/3: Pensions: Adapting our requirements for a changing market

Millions of people could get more support with their pensions under new proposals | FCA

• On 11 December 2024, the FCA published the findings of their review into firms’ approaches to completing the Consumer Duty Board report. The findings noted included: that good reports utilised high quality data; had detailed sections on the four focus areas of the consumer duty; and evidence of clear processes for the reports production. Reports that required improvement lacked in data quality, neglected details in action plans for improvement and failed to consider outcomes for different groups of customers. 

Consumer Duty Board Reports: good practice and areas for improvement | FCA

• On 11 December 2024, the FCA published the results of their thematic review into firm’s approaches to complaints and root cause analysis. In particular, the report underlined the importance of firms ensuring that their conclusions are all supported by appropriate data.

Complaints and root cause analysis: good practice and areas for improvement | FCA

• On 09 December 2024, the FCA responded to the treasury’s post Mansion House remit letter.  The response focused on: methods to facilitate growth in the financial services sector; an outline of FCA strategy between 2025-2030; the importance of the UK maintaining an international leadership position in financial services; and the potential for the FCA to focus more on growth in the financial services sector, rather than risk. 

FCA's response to Treasury remit letter 2024

• On 09 December 2024, the FCA set out their focus areas under the consumer duty. The FCA announced three cross-cutting projects: review of board/governing body reports and complaints and root cause analysis; review of treatment of customers in vulnerable circumstances; and review of the consumer support outcome and supporting informed decision-making. The FCA also set out further priorities for enhancing understanding of the price and value outcome as well as sector specific priorities.

Our Consumer Duty focus areas | FCA

• On 06 December 2024, the FCA published their quarterly consultation paper (CP24/26). The FCA is proposing to make clarificatory amendments to the anti-greenwashing rule and SDR. Consultation for these proposed amendments closed on 13 January 2025. 

CP24/26: Quarterly Consultation Paper No 46 

• On 06 December 2024, the FCA released a blog reflecting on the impact of the sustainable investment product regime. 

Establishing trust in sustainable investment products | FCA

• On 13 December 2024, ESMA put forward Q&As on the application of the guidelines on funds’ names using ESG or sustainability related terms. The Q&As relate to green bonds, the convergence on “meaningfully investing in sustainable investments” and the definition of controversial weapons. 

ESMA puts forward Q&As on the application of the Guidelines on funds’ names

• On 12 December 2024, ESMA published a consultation paper on draft regulatory technical standards to determine requirements for which loan-originating AIFs are to comply in order to maintain an open-ended structure. The requirements include: sound liquidity management systems; the availability of liquid assets; stress testing; and appropriate redemption policies. The consultation is the first stage in the development of regulatory technical standards. The consultation closes on 12 March 2025.

ESMA34-1985693317-1085 Consultation Paper on the draft regulatory technical standards on open-ended loan-originating AIFs under the AIFMD

• On 12 December 2024, Regulation (EU2024/3005) of the European Parliament and of the Council of 27 November 2024 was published in the Official Journal of the European Union. The regulation seeks to establish a common regulatory framework for ESG ratings in order to increase the transparency and integrity of ESG rating providers. The regulations came into force on 1 January 2025 and apply from 2 July 2026. 

Regulation - EU - 2024/3005 - EN - EUR-Lex