Share on LinkedInShare on LinkedIn

ARTICLE · 09 AUGUST 2023

Liquidity Streams: Recent Developments In Fund Liquidity Regulation

Macfarlanes LLP
Macfarlanes LLP
Contributor
Macfarlanes LLP

Macfarlanes LLP

Macfarlanes is a distinctive London-based law firm with a unique combination of services built and...

View firm profile
Explore more from Macfarlanes LLP

Within a week in July there has been a stream of regulatory developments in relation to fund liquidity risk management.

United KingdomFinance and Banking
Gavin Haran
Gavin Haran
Lora Froud
Lora Froud
Alexandra Green
Alexandra Green
Michael Sholem
Michael Sholem

Within a week in July there has been a stream of regulatory developments in relation to fund liquidity risk management. These developments include two sets of recommendations from global standard-setters, the publication of the FCA's review of firm's liquidity management frameworks together with a letter directed to asset management CEOs, and liquidity management as a contested issue in several EU legislative negotiations.

In this note, we briefly summarise what has happened and why, and our recommendation that managers should consider all these developments when reviewing their own arrangements, as regulators are increasingly requiring firms to do.

The FCA's multi-firm review

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

FCA Finalises Cryptoasset Perimeter Guidance Ahead Of The New UK Regime

The Financial Conduct Authority has released comprehensive perimeter guidance for the UK's new regulated cryptoasset activities regime, clarifying when firms will need authorization and how the regulatory framework applies to qualifying cryptoassets and stablecoins. The guidance addresses critical questions about scope, territorial application, and the narrower "by way of business" test that determines which entities fall under the new regulatory requirements.
United KingdomFinance and Banking
Katten
Katten
Article

The Future Of Islamic Finance: Insights From IFN UK Forum 2026

Islamic finance is experiencing rapid global expansion, with assets approaching US$6tn and record sukuk issuance attracting non-traditional investors. The convergence of Shariah-compliant and sustainable investing is creating new opportunities, while AAOIFI Standard No. 62 and tokenisation developments are reshaping how Islamic finance structures are designed and implemented across international markets.
United KingdomFinance and Banking
Walkers
Walkers
Article

Investment Management Update - September 2026

The Financial Conduct Authority has released a comprehensive package of regulatory updates and findings covering investment management, wealth management, and consumer protection. Key developments include reforms to MiFID costs and charges disclosures, remuneration code changes, AIFM regime overhauls, and detailed reviews of firms' Consumer Duty compliance, financial crime controls, and governance frameworks.
United KingdomFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

New AIM Rules (August 2026)

The London Stock Exchange has implemented sweeping reforms to the AIM Rules, fundamentally reshaping admission requirements, transaction thresholds, and governance obligations for companies on the Alternative Investment Market. These changes eliminate longstanding requirements like working capital statements and corporate governance codes while introducing new features such as capital access windows and special voting shares, marking the most significant overhaul of AIM regulations in recent years.
United KingdomFinance and Banking
Shoosmiths LLP
Shoosmiths LLP
Article

Nearly Out Of PERG-atory – But Not Quite Yet: Good News As The FCA Finalises PERG 18 On Cryptoassets, But With Even More Legal Changes To Come

Cryptoasset firms face a rapidly evolving regulatory landscape as the FCA's authorisation gateway opens on 30 September 2026. With the Financial Services and Markets Act 2000 (Cryptoassets) (Miscellaneous Amendments) Regulations 2026 laid before Parliament and the FCA's finalised PERG 18 guidance published within 24 hours, firms must navigate significant perimeter changes including new stablecoin payment exclusions.
United KingdomFinance and Banking
Travers Smith LLP
Travers Smith LLP
Article

Modernising UK Payments: HM Treasury’s Proposed Overhaul Of The Payment Services Regime

On 14 July 2026, HM Treasury published its long-awaited consultation on modernising the UK’s payment services and electronic money regulatory framework. The consultation is part of the Government’s National Payments Vision agenda, which aims to ensure that the UK has a trusted, world-leading payments ecosystem delivered on next generation technology, while preserving choice for consumers and businesses.
United KingdomFinance and Banking
A&O Shearman
A&O Shearman
Article

Financial Regulation Weekly Bulletin - 10 September 2026

This weekly bulletin examines critical developments in UK financial regulation, including the FCA's findings on systemic operational resilience from its Defence, Security, and Resilience Lab exercise, the government's comprehensive consultation on modernising corporate reporting frameworks, and progress on the Financial Services and Markets Bill through Parliament. The bulletin also covers international regulatory updates on cyber resilience for financial market infrastructures, sustainable finance disclosu
United KingdomFinance and Banking
Slaughter and May
Slaughter and May
Article

SFDR 2.0 – European Parliament Negotiating Position: The Stage Is Set For Trilogue

The European Parliament has published its negotiating position on SFDR 2.0, setting the stage for trilogue negotiations between the Commission, Parliament and Council. With the asset management industry hoping for relief from the complexities of SFDR 1.0, the Parliament's proposals claim to simplify the regime while maintaining credibility of sustainability-related investments.
United KingdomFinance and Banking
Travers Smith LLP
Travers Smith LLP
Article

Reward Autumn Update 2026

The autumn 2026 edition of the Reward update examines significant proposals to reform directors' remuneration reporting requirements, including changes to the DRR and removal of the annual shareholder advisory vote. It also covers FCA consultation on solo-regulated firms' remuneration, the impact of Employment Rights Act changes on share plans, equal pay reform proposals, and updates to AIM rules affecting corporate governance and remuneration disclosure.
United KingdomEmployment and HR
Macfarlanes LLP
Macfarlanes LLP
Article

Broadcom/VMware: EU General Court Again Weighs In Favour Of Commission’s Broad Information Gathering Powers

The European Commission's broad information-gathering powers under EU competition law have been reinforced by the General Court's dismissal of Broadcom's challenge to document production requests. The case raises critical questions about the extent to which the Commission can compel production of documents held overseas that are subject to legal professional privilege in other jurisdictions, particularly communications with non-EU qualified external counsel.
European UnionAntitrust/Competition Law
Macfarlanes LLP
Macfarlanes LLP
Article

Investment Management Update - September 2026

The Financial Conduct Authority has released a comprehensive package of regulatory updates and findings covering investment management, wealth management, and consumer protection. Key developments include reforms to MiFID costs and charges disclosures, remuneration code changes, AIFM regime overhauls, and detailed reviews of firms' Consumer Duty compliance, financial crime controls, and governance frameworks.
United KingdomFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

Investing In Infrastructure: The Capital Stack

The infrastructure capital stack is undergoing significant transformation as equity markets consolidate at the top while creating mid-market opportunities, private debt emerges as a bankability indicator for maturing sectors, and fund finance structures become increasingly sophisticated. This evolution is reshaping how capital is deployed, structured, and exited across the infrastructure investment landscape...
United KingdomFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

Sponsored Repo And US Treasury Central Clearing – What The Buy-side Needs To Know

The US Treasury repo market faces a fundamental transformation as SEC rules mandate central clearing for most Treasury repurchase transactions by June 2027. This regulatory shift is accelerating buy-side adoption of "sponsored repo" arrangements, requiring firms to navigate new operational frameworks, documentation requirements, and clearing relationships. Understanding the mechanics of sponsored membership and preparing for compliance will be critical for buy-side participants seeking to maintain efficient
United StatesFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

Few Surprises, As The CMA Finalises Its Revised Approach To Merger Efficiencies

The UK Competition and Markets Authority has formalised its new approach to assessing efficiency arguments in merger control cases, marking a significant shift toward a more holistic evaluation framework. This updated guidance, which emerged from the CMA's 4Ps initiative, introduces the concept of Rivalry-Enhancing Efficiencies and establishes clearer pathways for merging parties to demonstrate competitive benefits.
United KingdomAntitrust/Competition Law
Macfarlanes LLP
Macfarlanes LLP
Article

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United KingdomTax
Macfarlanes LLP
Macfarlanes LLP
Article

The New EU FDI Screening Regulation: (Un)welcome Changes For Dealmakers

The European Union's new foreign direct investment screening regulation introduces significant procedural improvements and standardised risk assessment criteria, while simultaneously expanding the scope of mandatory filings and eliminating preferential treatment for allied investors. Understanding how these changes will affect cross-border transactions and what steps dealmakers should take during the 18-month transition period is crucial for navigating the reformed regulatory landscape.
GlobalInternational Law
Macfarlanes LLP
Macfarlanes LLP