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ARTICLE · 31 JULY 2024

UK Compliance Update: FCA Rules Will Allow CSA-Style Payments For Research From 1 Aug. 2024

McDermott Will & Schulte
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The UK Financial Conduct Authority ("FCA") has released the final rules on the Payment Optionality for Investment Research in its PS 24/9.

GlobalFinance and Banking
Anna Maleva-Otto
Anna Maleva-Otto
William J. Barbera
William J. Barbera
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The UK Financial Conduct Authority ("FCA") has released the final rules on the Payment Optionality for Investment Research in its PS 24/9.1 The FCA rules refer to this new research payment structure as "joint payments for third-party research and execution services"; in fact, it is based on a commission sharing arrangement ("CSA Option") combined with detailed procedural and operational safeguards, including budgeting, valuation and client disclosure obligations. Managers who intend to take up the CSA Option will need to ensure the procedural safeguards are appropriately implemented in written compliance policies, CSA agreements or similar, client agreements and periodic client reporting, as appropriate.

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