RegBrief, Vol VI

This is the sixth edition of RegBrief, the quarterly bulletin of the Arthur Cox Financial Regulatory Group. RegBrief contains a summary of certain developments and is neither a complete nor a definitive statement of law or of regulation. Specific legal advice should be obtained before taking any action.

IRISH LEGAL AND REGULATORY DEVELOPMENTS

Mortgage Arrears

• New Code: the revised Code of Conduct on Mortgage Arrears (CCMA) took effect on 1 July 2013. The Briefing issued by the Arthur Cox Finance Group on 3 July 2013 on the revised CCMA is available here.
• Internal Guideline: on 24 September 2013, following on from the publication in March 2013 of its Mortgage Arrears Resolution Targets (see our March 2013 Briefing here), the Central Bank published the final version of its Internal Guideline on Sustainable Mortgage Arrears Solutions (the Internal Guideline) for use by its supervisory teams when auditing the results of the Mortgage Arrears Resolution Targets (the Internal Guideline does not apply to measuring a bank's compliance with the CCMA). A draft of the Internal Guideline had first been published by the Central Bank on 24 July 2013.
• Ammending Legislation: the Land and Conveyancing Law Reform Act 2013 was signed into law on 24 July 2013. The Act is designed to rectify the issues which were first raised by Dunne J in the 2011 High Court decision in Start Mortgages Ltd & Ors v Gunn & Ors [2011] IEHC 275 regarding repossession proceedings in respect of registered land. Further detail is included in our recently published update on Legal Issues in Residential Mortgages (available here).
• New Targets: on 17 September 2013 the Central Bank announced that it had, in agreement with the Troika, set further targets for the banks as regards offering sustainable solutions to, and concluding arrangements with, customers in 90+ days mortgage arrears. Those targets are as follows:
• 70% of those customers must be offered a sustainable solution by 31 March 2014
• concluded arrangements must be reached with 15% of those customers by 31 December 2013
• concluded arrangements must be reached with 25% of those customers by 31 March 2014

Central Bank Reform Act 2010

On 19 September 2013 the last uncommenced provision of the Central Bank Reform Act 2010 was commenced by the Minister for Finance. This provision inserts a section into the Central Bank Act 1942 requiring the Central Bank to submit a strategic plan to the Minister for Finance every 3 years.

Central Bank (Supervision and Enforcement) Act 2013

This was signed into law on 11 July 2013 and came into effect on 1 August 2013, with the exception of Section 72 (the new 'name and shame' powers for the Financial Services Ombudsman) which came into effect on 1 September 2013. Our Briefing on the new Act is available here

Personal Insolvency Act 2012 (the PIA)

On 9 September 2013 the Insolvency Service of Ireland (the ISI) opened for business, having authorised a number of approved intermediaries (for the purposes of Debt Relief Notices) and personal insolvency practitioners (for the purposes of Debt Settlement Arrangements and Personal Insolvency Arrangements).

Following the amendment of the PIA by the Courts and Civil Law (Miscellaneous Provisions) Act 2013, the ISI also issued a number of regulations which, among other matters, deal with:

• the fees for the authorisation and renewal of personal insolvency practitioner authorisations
• the fees and forms to be used in connection with applications for Debt Relief Notices or for Protective Certificates relating to Debt Settlement Arrangements and Personal Insolvency Arrangements
• account-preservation and recordkeeping obligations for personal insolvency practitioners
• the information that a debtor must provide in relation to his/her financial affairs and the form of prescribed financial statement that a debtor must complete
• restrictions on dealings with property above a certain value
• information to be included in a Schedule of Creditors
• procedures for the conduct of creditors' meetings

We will shortly be publishing a detailed updated Briefing on the PIA and the above regulations. Commencement orders (to be signed by the Minister for Justice) in relation to the sections of the PIA and the Courts and Civil Law (Miscellaneous Provisions) Act 2013 that will reform the existing Bankruptcy Act 1988 are still awaited.

Credit Unions

• Legislation: on 1 July 2013, the Minister for Finance published his implementation plan for those sections of the Credit Union and Co- Operation with Overseas Regulators Act 2012 that had not been commenced with the aim of allowing time for credit unions to prepare for the changes required by that Act. The provisions of the Act regarding restructuring and stabilisation came into force shortly after the Act was signed. Various other "standalone" sections came into force on 1 August 2013 (allowing credit unions the right to appeal certain Central Bank decisions to the Irish Financial Services Appeals Tribunal and disapplying certain banking legislation to credit unions).

On 11 October 2013, provisions relating to new governance and prudential requirements for credit unions were commenced (with the exception of certain provisions, including those relating to boards of directors).

The remaining sections are expected to be commenced in two stages as follows:

• March 2014: reductions in board numbers, the submission of annual compliance statements to the Central Bank and procedural provisions in relation to Board Oversight Committees
• Q2 2014: other prudential measures regarding savings, borrowing, lending, investments, reserves and liquidity
• Regulation: separately, the Central Bank published its draft Credit Union Handbook on 1 July 2013, seeking comments by 31 July 2013. The final version of Credit Union Handbook was then published on 12 September 2013 and included details of the Fitness and Probity Regime for Credit Unions (which commenced on 1 August 2013) and the new governance and prudential requirements for credit unions (many of which apply to credit unions from 11 October 2013, but some of which remain to be commenced). Further detail on the Fitness and Probity Regime for Credit Unions was also set out in the Central Bank's 8 August 2013 Regulatory Transactions Review and the Central Bank continues to update its dedicated webpage on fitness and probity for credit unions (most recently updating the Guidance on Fitness and Probity for Credit Unions, the PCF Information Guidance and PCF Resignation Guidance at the beginning of October 2013).

Central Bank Consultation Papers

The Central Bank has published a number of consultation papers over recent months in relation to:

• CP67: process improvements and service standards in respect of the authorisation process for regulated firms, funds and intermediaries
• CP68: the types of alternative investment funds under the Alternative Investment Fund Managers Directive (Directive 2011/61/EU) (AIFMD) and unit trust schemes under the Unit Trust Act 1990
• CP69: its review of the Corporate Governance Code for Credit Institutions and Insurance Undertakings
• CP70: as Debt Management Firms are now regulated by the Central Bank following the enactment of the Central Bank (Supervision and Enforcement) Act 2013, the authorisation requirements and standards for Debt Management Firms and the amendment of the Minimum Competency Code 2011. In early August 2013, the Central Bank also published a Guidance Note for Completing an Application for Authorisation as a Debt Management Firm, Introductory Information and Preliminary Meeting Requirements for Debt Management Firms and an Application Form for the Notification of Other Places of Business. On 11 October 2013, following the end of the CP70 consultation period, the Central Bank then published its Authorisation Requirements and Standards for Debt Management Firms, together with its Application Form for Authorisation as a Debt Management Firm
• CP71: proposed client asset regulations and guidance intended to enhance the Central Bank's client asset regime by minimising the risk of loss or misuse of client assets while the firm is a going concern and, in the event of a firm's insolvency, to return those assets to clients as efficiently and cost effectively as possible
• CP72: proposed changes to the Handbook of Prudential Requirements for Authorised Advisors and Restricted Intermediaries
• CP73: the changes that it proposes to introduce to strengthen its supervisory framework in relation to non-life insurers and reinsurers
• CP74: its proposed approach to the various provisions contained in the new Capital Requirements Directive (Directive 2013/36/EU of 26 June 2013) and the new Capital Requirements Regulation (Regulation EU 575/2013 of 26 June 2013) (together known as CRD IV) in respect of which the Central Bank, as competent authority, can exercise discretions

Financial Services Ombudsman (FSO)

On 21 August 2013 the FSO published his Bi-Annual Review (January – June 2013). In the accompanying press release he noted that, to address the fact that the same issues and complaint types are recurring each year, the FSO's office is introducing a new approach. This requires:

• complainants to engage with the relevant financial institution in the manner set out in the Consumer Protection Code 2012 before approaching the FSO and
• financial institutions to document their efforts to deal with those complaints "comprehensively and fairly" before referring consumers to the FSO The FSO also made particular reference to his new power, under the Central Bank (Supervision and Enforcement) Act 2013, to publish the complaints records of individual financial institutions in future reviews.

Other Developments

• Payment Protection Insurance (PPI): on 3 October 2013 the Central Bank published an update regarding its ongoing investigation into the sale of PPI by 11 firms from July 2007 onwards. Of the 350,000 policies included in the review, over 50% have been reviewed with 1 in 5 found to have breached the requirements of the Consumer Protection Code. Approximately €25 million has been identified for refund so far, and the Central Bank's aim is to conclude the review, and ensure that all affected consumers are contacted by the firms involved, by the end of 2013.
• Freedom of Information Bill: the Minister for Public Expenditure and Reform published the draft Freedom of Information Bill on 24 July 2013. Certain bodies that are currently outside of the scope of the existing freedom of information (FOI) regime will now be brought within its remit including:
• the Central Bank, other than in respect of records that are subject to professional secrecy obligations (in particular under EU law and Eurosystem requirements)
• public financial bodies, such as the National Treasury Management Agency, National Asset Management Agency, National Pension Reserve Fund, and the National Development Finance Agency who will all be brought within the scope of the FOI regime for the first time. This will be subject, in particular, to the maintenance of strict confidentiality of their engagement with commercial counterparties, for example, in securing external private finance for the State.

AIFMD:

• legislation: the Minister for Finance signed the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013) into law on 16 July 2013. These regulations gave effect to the AIFMD and are supplemented by the Central Bank of Ireland's AIF Rulebook. The equivalent UK regulations (the Alternative Investment Fund Managers Regulations 2013 (S.I. 2013/1773)) were also made on 16 July 2013, and entered into force on 22 July 2013
• regulation: on 19 July 2013, the Central Bank published the most recent version of its AIF Rulebook and has also published its Application Form for Authorisation as an AIFM and related authorisation and postauthorisation documentation The fourth edition of its AIFMD Q&A was also published on 30 September 2013.
• Fitness and Probity: the Central Bank's Fitness and Probity Service Standards Report for January-June 2013 was published on 25 July 2013.
• Pilot Programme for Multi-Debt Restructuring: on 24 July 2013 the Central Bank announced that lenders participating in this programme had decided to appoint StepChange Debt Charity as the service provider to operate the programme. The programme will cover approximately 750 cases where participating borrowers owe debts to multiple lenders. »» Loan Origination by Investment Funds: on 19 July 2013 the Central Bank published a Discussion Paper on loan origination by investment funds seeking views on a range of issues set out in that paper which must be considered if investment funds are permitted to source assets by directly originating loans. In particular the Central Bank sought views on whether the public good could be served by relaxing the current regulatory constraints on investment funds originating loans, what shadow banking risks could be raised if those constraints were relaxed (and how those risks could be mitigated) and whether the Central Bank's current AIF Rulebook affords sufficient protections to investors if investment funds are allowed to originate loans.
• Related Party Lending: on 31 July 2013 the Central Bank published a Related Party Lending External FAQ to address commonly asked questions, based on the Central Bank's experience in apply the Related Party Lending Code.
• Electronic Money Institutions: on 1 July 2013 the Central Bank published a Revised Guidance Note on Completing an Application for Authorisation as an Electronic Money Institution to give applicants further detail on how to meet the requirements of the European Communities (Electronic Money) Regulations 2011 (S.I. 183/2011).
• Markets Update: the Central Bank published two further editions of its Markets Update in July, covering topics such as AIFMD, the Markets in Financial Instruments Directive (Directive 2004/39/EC) (MiFID), benchmark-setting, the Short Selling Regulation (Regulation (EU) No. 236/2012) and the Prospectus Directive (Directive 2003/71/EC).
• Bureaux de Change: on 16 July 2013 the Central Bank published a Guidance Note for Bureaux de Change Businesses together with an update to its 2011 Authorisation Requirements and Standards for Bureaux de Change businesses.

EUROPEAN DEVELOPMENTS

Single Supervisory Mechanism (SSM)

On 12 September 2013 the European Parliament (the Parliament) voted to adopt, at first reading, the proposed legislation which will establish the SSM under which specific tasks will be conferred on the European Central Bank (ECB) regarding the prudential supervision of credit institutions. On 9 October 2013, the Parliament also approved the form of Inter-Institutional Agreement (IIA) between it and the ECB on related procedural cooperation issues. The IIA will enter into force on the later of the date that it is signed, or the date that the SSM enters into force.

The two regulations that comprise the SSM were formally adopted on 15 October 2013 by the Council of the European Union (the Council). They are expected to be published in the Official Journal of the European Union (the OJ) shortly and the ECB will assume its supervisory role 12 months later.

In a speech on 5 September 2013, an ECB Executive Member outlined the ECB's ongoing preparations for the SSM, including its work on constructing a comprehensive database with information on all euro area banks and its intention to form a team of national and European supervisors for each banking group to allow them to share know-how – the ECB indicated that it would consult on the detailed rules of this part of its supervisory model in Autumn 2013.

Single Resolution Mechanism (SRM)

On 10 July 2013 the European Commission (the Commission) announced that it had proposed an SRM for banking union, and published a set of FAQs. The SRM is intended to apply the substantive rules of bank recovery and resolution set out in the proposed Recovery and Resolution Directive (RRD). Under the SRM, the Commission's intention is that the ECB will indicate when a bank in the euro area or in a Member State that participates in banking union is experiencing serious financial difficulties and needs to be resolved. A Single Resolution Board will then, using broad powers, develop an approach for resolving the bank. We understand that the Council aims to reach agreement on the SRM by the end of 2013 so that the proposal can be adopted before May 2014 however the SRM proposal has been the subject of much debate in recent weeks, in particular in light of the opinion issued by the Legal Service to the Council on 7 October 2013 which expressed concerns regarding the powers that the SRM would confer upon the new Single Resolution Board. The SRM proposal is currently listed for consideration by the Parliament at its 10-13 March 2014 plenary session.

Residential Mortgages Directive

On 10 September 2013 the Parliament announced that it had adopted a legislative resolution on the proposed directive on credit agreements relating to residential property. The Parliament also confirmed that it had voted to include rules:

• giving borrowers the right to repay the loan early and giving lenders the right to fair compensation for such early repayment
• prohibiting penalties for early repayment by borrowers
• requiring lenders to give warnings for loans denominated in foreign currency or to give borrowers the opportunity to change the currency
• stipulating that the return of collateral, such as the property itself, will suffice to repay a loan, provided the lender and borrower expressly agree to this in the contract

Notably, the Parliament's press release stated that, although the Parliament had adopted the final wording of the resolution, Parliament wants EU Member States to undertake to properly enforce the rules throughout the EU "before approving the rules overall".

Parliament is currently scheduled to consider the proposed directive at its 19 November 2013 plenary session.

Payment Services Directive and Interchange Regulation

On 24 July 2013 the Commission published its proposal for a revised Payment Services Directive together with its proposal for a Regulation on interchange fees for card-based payment transactions (the PSD2 Proposals). The objectives of the new directive (which will amend the existing Payment Services Directive (Directive 2007/64/EC)) are to further integrate the European payments market, improve the "level playing field" for payment services providers, encourage lower prices for payments, ensure high levels of consumer protection and payment security and facilitate the development of common technical standards and interoperability. The PSD2 Proposals are currently scheduled to be considered by Parliament in its 2-3 April 2014 plenary session.

Second Electronic Money Directive (Directive 2009/110/EC) (EMD2)

On 19 September 2013, the Commission published a series of Conformity Assessments (dated 8 February 2013) which it had carried out to determine how Member States had transposed EMD2 into national law. As regards Ireland, the Commission stated that the "...general outcome of the conformity assessment is that of conformity" however some small instances of partial, or non, conformity were highlighted.

Regulation on OTC derivatives , CCPs and trade repositories (Regulation 648/2012) (EMIR)

• Q&A: the European Securities and Markets Authority (ESMA) updated its EMIR Q&A on 5 August 2013.
• Reporting: on 8 August 2013 ESMA published its final report to the Commission proposing that the start date for reporting exchange trade derivatives (ETD) to trade repositories be postponed by one year to January 2015. However, ESMA has now indicated that the Commission does not propose to endorse that delay. If the Commission does not endorse the delay, ESMA intends to publish Q&A on ETD reporting before the start of the reporting obligation.
• Equivalence: on 3 September 2013 ESMA published its advice to the Commission on the equivalence of the regulatory regimes of certain non-EU countries under EMIR. Its second set of advice on third country equivalence was then published on 2 October 2013. The rules of those non-EU countries were compared with EMIR's requirements regarding central clearing, reporting, central counterparties (CCPs), trade repositories, non-financial counterparties and risk mitigation techniques for cleared trades.
• Timetable: on 13 September 2013 ESMA published an updated version of its EMIR implementation timetable. The key change in the implementation timeline related to the registration of the first trade repositories - ESMA now expects to make those first registration decisions after 7 November 2013, meaning that counterparties' reporting to trade repositories is not expected to start before February 2014.
• Portfolio reconciliation and dispute resolution: EMIR's requirements in relation to portfolio reconciliation and dispute resolution came into effect on 15 September 2013. Our Capital Markets Group's Briefing on those requirements can be found here.
• Cross-border application: on 26 September 2013 ESMA announced that the Commission had extended the deadline for it to deliver draft regulatory technical standards (RTS) on the cross-border application of EMIR from 25 September 2013 to 15 November 2013.
• CCP colleges: on 3 October 2013, ESMA published the official translations of its guidelines and recommendations on written agreements between members of CCP colleges (the final version of which had been published in June 2013).
• Delegated Regulations:
• supervisory colleges: on 13 September 2013 Commission Delegated Regulation 876/2013 containing RTS on colleges for CCPs was published in the OJ. The RTS set out in the Delegated Regulation, required under Article 18 of EMIR, address the operational organisation and governance of supervisory colleges that must be set up to scrutinise the application of a CCP for authorisation under EMIR. The Commission had adopted the RTS in May 2013 and, in July 2013, the Council had confirmed that it would not object to the Delegated Regulation. The Delegated Regulation entered into force 20 days following its publication in the OJ
• exempted entities; fees: on 11 October 2013 the Council confirmed that it will not object to the two Commission Delegated Regulations adopted by the Commission in July 2013 relating to exempted entities and fees charged by ESMA to trade repositories. Unless Parliament now objects, the regulation relating to fees will enter into force on the third day following its publication in the OJ, and the regulation relating to exempted entities will enter into force on the twentieth day following such publication.

CRD IV

On 8 July 2013 the Council published corrigenda to CRD IV correcting a number of dates in the original texts of both the directive and the regulation. The Commission updated its FAQs on CRD IV in July 2013, explaining the regulatory and implementing technical standards that will be required, detailing the role of the European Banking Authority (EBA) in building a Single Rulebook and clarifying related matters. The EBA has also recently issued numerous consultation papers on particular aspects of CRD IV, and has recently agreed revised deadlines with the Commission for the production of various regulatory and technical standards required under CRD IV (in particular in relation to own funds).

AIFMD

On 13 August 2013 ESMA published the final version of its Guidelines on Key Concepts of the AIFMD designed to ensure that there is consistent application of the concepts which make up the definition of an alternative investment fund. The guidelines take effect 2 months after their publication. This followed the publication, on 1 August 2013, of ESMA's Practical arrangements for the late transposition of the AIFMD and the publication, on 3 July 2013, of ESMA's Guidelines on sound remuneration policies under the AIFMD. On 1 October 2013, ESMA also published its final report containing guidelines on reporting obligations under Articles 3 and 24 of AIFMD, clarifying the information that alternative investment fund managers (AIFMs) should report to national competent authorities (NCAs), the timing of those reports and the procedures that are to be followed when AIFMs move from one reporting obligation to another. There is now a 2 month period within which NCAs must notify ESMA whether or not they comply or intend to comply with these guidelines.

Money Market Funds

On 4 September 2013 the Commission published a proposed Regulation on money market funds (MMFs) in light of its concerns regarding the link between MMFs and the banking sector, and the potential for large-scale runs/ early MMF share redemptions. The proposed regulation seeks to prescribe levels of daily and weekly liquidity, clear labelling, a capital buffer, customer profiling policies and requirements for internal credit risk assessment. The Commission's intention is that the regulation will apply to all MMFs that invest in money market instruments, whether or not they are part of the UCITS or AIFMD frameworks. The Commission hopes that the regulation will be directly applicable throughout the EU by the end of 2014, and it is currently scheduled for consideration by the Parliament at its 14-17 April 2014 plenary session.

Fourth Money Laundering Directive

The European Data Protection Supervisor (EDPS) published an opinion on 4 July 2013 in relation to the Commission's proposals for a Fourth Money Laundering Directive (MLD4) and related regulation on information accompanying transfers of funds. The EDPS recommended that the application of EU data protection law should be more explicit in the proposals, that given the intrusive nature of anti-money laundering obligations, the rights of data subjects to be informed of the analysis or transfer of their personal information should be clearly outlined and that specific provisions on international transfers should be added, taking proportionality principles into account.

A partial compromise text on MLD4 has been made available by the Council Presidency (dated 30 August 3013) and MLD4 is currently scheduled to be considered by the Parliament at its 10-13 March 2014 plenary session.

Amendment to Prospectus Regulation

On 8 August 2013 Commission Delegated Regulation (EU) No. 759/2013 was published in the OJ and came into force on 28 August 2013. It amended the Prospectus Regulation (Regulation (EC No. 809/2004) to clarify the disclosure requirements for convertible and exchangeable debt securities.

Benchmarks

On 18 September 2013 the Commission published its draft text for a proposed Regulation on the regulation of benchmarks, taking account of the principles recently agreed by the International Organization for Securities Commissions. The proposed regulation is designed to improve governance and controls relating to benchmarks, improve methodologies, ensure protection for both consumers and investors and ensure the supervision and viability of important benchmarks. The proposed regulation does not just deal with interest rate benchmarks such as EURIBOR and LIBOR, but also extends to cover commodity benchmarks, benchmarks used to reference financial instruments admitted to trading or traded on a regulated venue and benchmarks used to measure the performance of investment funds.

This Commission proposal (the final proposed text of which was published on 24 September 2013) will now need to be considered and adopted by the Parliament and the Council. The Commission has stated that it expects this process to be completed by the end of the Parliament's current mandate, with the regulation to come into effect one year later.

Solvency II (Directive 2009/138/EC)

On 27 September 2013 the European Insurance and Occupational Pensions Authority (EIOPA) published its final guidelines on the preparation for Solvency II which it stated that it plans to issue in all European languages on 31 October 2013, with a view to the guidelines applying from 1 January 2014 (EIOPA will give NCAs 2 months from 31 October 2013 to signal whether or not they intend to comply with the guidelines, and will also require the submission of implementation progress reports in February 2015).

On 2 October 2013, the Commission then published a legislative proposal for a further directive which would extend the transposition date for Solvency II to 31 January 2015, and extend the application date to 1 January 2016. The proposed directive would also extend the dates on which existing insurance and reinsurance directives are to be repealed to 1 January 2016.

MiFID

ESMA published, on 1 October 2013, the official translations of its guidelines and recommendations on remuneration policies and practices under MiFID (the final version of those guidelines had been published by ESMA in June 2013).

Work Programmes

The European Supervisory Authorities (ESMA, the EBA and EIOPA) have published their 2014 Work Programmes in recent weeks. Key 2014 focus areas for each authority are as follows:

• ESMA: the proposed Markets in Financial Instruments Regulation, the proposal for the regulation of packaged retail investment products (PRIPs), revisions to MiFID, revisions to the Market Abuse Directive (Directive 2003/6/EC) and the submission of draft technical standards under both the CRA III Regulation (Regulation 462/2013) and the proposed Regulation on improving securities settlement and central securities depositaries (the CSD Regulation).
• EBA: work required under CRD IV and the proposed RRD, and fulfilling mandates imposed in it under the proposed Residential Mortgages Directive, the PSD2 Proposals and the proposed Directive on payment accounts.
• EIOPA: finalising technical standards and guidance required in relation to Solvency II and assessing the impact of any advice on standards proposed under the proposed revised Insurance Mediation Directive (IMD2).

Update on dates for consideration of other regulatory measures

• MiFID II: a timetable setting out the likely dates for adoption of the MiFID II proposals (a directive and a regulation that will amend both MiFID and EMIR) has not yet been published by the Commission however given the volume of Level 2 measures that will be required, the implementation date is not expected to be before 2015. The Parliament has listed 25 February2014 as indicative date for considering MiFID II in plenary session.
• Insider dealing and market manipulation: regulation currently scheduled to be considered at Parliament's 13-16 January 2014 plenary session.
• RRD: directive currently scheduled to be considered at the Parliament's 3-6 February 2014 plenary session.
• European long-term investment funds: regulation currently scheduled to be considered at Parliament's 3-6 February 2014 plenary session.
• CSD Regulation: regulation currently scheduled to be considered at Parliament's 3-6 February 2014 plenary session.
• Key Information Document for PRIPs: regulation currently scheduled to be considered at Parliament's 24-27 February 2014 plenary session.
• Omnibus II: directive currently scheduled to be considered at Parliament's 10-13 March 2014 plenary session.
• IMD2: directive currently scheduled to be considered at Parliament's 10-13 March 2014 plenary session.
• Payment Accounts: directive currently scheduled to be considered at Parliament's 10-13 March 2014 plenary session.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.