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What is ‘policy work’?

UKSA will get involved in any area of activity that supports the rights and responsibilities of independent shareholders and, where appropriate, all savers under our banner of ‘Savers Take Control’ Savers Take Control | UKSA

The majority of the policy work is responses to government, regulatory and standard setters’ consultations, but a significant amount is proactive campaigning to remove inequitable treatment of individual shareholders, investors and savers, for example:

IFRS’ consultation paper on sustainability standards

HM Treasury Financial Services Future Regulatory Framework Review

Northern Rock Action Group issue progress status

 

The Policy Team members listed alphabetically

Mohammed Amin, Dean Buckner, Charles Henderson, Sue Milton, Peter Parry.

Please contact Dean Buckner, the Policy Director, at admin@uksa.org.uk if you would like to join the team. 

Current and recent activity

Campaigns

No update to the news published last month and the inks to the latest information on the Northern Rock Shareholder Action Group and the Amigo Shareholders Action Group remain the same.

Our support continues of the Prudential Assurance Company policyholders who object to ‘Part VII’ process of transferring insurance obligations from Prudential to Rothesay Life.  The related hearing is set for the 8th November 2021.  You will see, from the first entry in the table below, that we have also formally responded to the FCA’s consultation.

Part VII of the Financial Services and Markets Act 2000 (FSMA) is a court-sanctioned legal transfer of some or all of the policies of one company to another.  Policyholders rely on this process being fair, transparent, accessible and understandable.

Our letter covering policy holders’ unanswered concerns about the application of the process, can be found here.

Working with 3rd parties

UKSA Policy Team members continue to contribute to and review CRUF’s comment letters, their way of responding to consultations.  The two main differences between UKSA’s and CRUF’s responses are that UKSA’s are focused on the retail investor with a UK perspective, and CRUF’s cover both retail and institutional investors as well as market analysts with a global perspective.  CRUF’s responses can be found Comment Letters - CRUF.

Consultations

Below is the latest list of the Policy Team’s consultation activity since our mid-August update.  If you are interested in getting involved in open items, please contact David Riches at admin@uksa.org.uk.

 

Agency

Title

Submission deadline

Response status

Information available 

Response available

FCA

GC21/3: Proposed changes to guidance on the FCA’s approach to the review of Part VII insurance business transfers.

31/8/21

Completed

here

here

 HMT

UK prospectus regime.

24/9/21

Completed – key points only.

Supporting  ShareSoc’s consultation response.

here

 

here

IASB

Third agenda consultation 2021.

27/9/21

In progress.

here

 

here

IASB

Management Commentary.

23/11/21

Not started.

here

 

 

IASB

Targeted Standards-Level Review of Disclosures.

12/01/22

Not started.

here

 

IASB

Supplier finance arrangements.

To be confirmed.

Not started.

 

 

FRC

Proposed Revisions to the Audit Firm Governance Code.

18/11/21

Not started.

here

 

 

TPR/FCA

Driving Value for Money in defined contribution pensions FCA DP21/3.

10/12/21

Not started.

here

 

 

Q3/Q4 2021 completed consultations 

 

FCA

DP21/1: Strengthening our financial promotion rules.

1/7/21

Agreed not to respond.

here

N/A

The UK Government Department of Business, Energy and Industrial Strategy (BEIS)

Restoring trust in audit and corporate governance.

8/7/21

Completed.

Joint response with ShareSoc.

And

Lead author on the CRUF response

here

here

and

here

FCA

CP21/13: A new Consumer Duty.

31/7/21

Completed

here

here

 

IASB

Business Combinations under

Common Control.

1/9/21

Agreed not to respond.

here

N/A

FCA

CP 21/17 Enhancing climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers

 

10/9/21

Agreed not to respond.

here

N/A

FCA

CP21/21: Primary Markets Effectiveness Review.

14/9/21

Agreed not to respond.

here

N/A

IASB

Addressing IFRS17 and IFRS9 conflicts.

30/11/21

Agreed not to respond.

here

 

N/A

Q2 2021 completed consultations 

 

BEIS

Restoring trust in audit and corporate governance.

8/7/21

Completed.

Joint response with ShareSoc.

And

Lead author on the CRUF response

here

here

and

here

FCA

DP21/1: Strengthening our financial promotion rules.

1/7/21

Agreed not to respond.

here

N/A

The Pension Regulator and the FCA

Pensions consumer journey: Call for Input document.

30/6/21

Agreed no to respond.

here

N/A

IASB

Regulatory Assets and Regulated Liabilities.

30/6/21

Agreed not to respond.

here

N/A

FCA

CP21/11: The stronger nudge to pensions guidance

29/6/21

Completed by John Hunter in a personal capacity.   

here

N/A

FCA

CP21/12 A new authorised fund regime for investing in long term assets.

25/6/21

Completed.

Joint response with ShareSoc.

here

here

BEIS

Consultation on BEIS mandatory climate-related disclosures requirements.

5/5/21

Completed.

 

here

here

FRC

Consultation and Impact Assessment on Proposal to Revise the UK’s Quality Management Standards.

19/3/21

Completed.

Joint response with ShareSoc.

here

here

PWC

Focus areas for investors in 2021.

N/A

Completed.

 

here

 

FRC

Revised review standard (ISRE (UK) 2410) for interim financial statements.

19/2/21

Completed.

Joint response with ShareSoc.

here

here

HMT

The Future Regulatory Framework (FRF) Review.

19/2/21

Completed.

here

here

 

UK Parliament Committees

Future of Financial Services post BREXIT transition.

19/2/21

Completed.

here

here

FRC

Proposal to revise ISA (UK) 240 (Updated January 2020) of Auditor's Responsibilities Relating to Fraud in an Audit of Financial Statements.

19/2/21

 

Completed.

Joint response with ShareSoc.

A separate, joint response with CRUF.

here

here

 

and

 

here

FRC

“A Matter of Principles”, the Future of Corporate Reporting.

5/2/21

Completed.

 

here

here

BEIS

Corporate Transparency and Register Reform

3/2/21

Completed.

Response is via CRUF.

here

 

here

IASB

Fraud And Going Concern In An Audit Of Financial Statements

1/2/21

Agreed not to respond.

here

N/A

UKEB

Draft comment letter on IASB’s Disclosures, Goodwill & Impairment project.

25/1/21

 

Completed.

here

here

FCA

Guidance for insolvency practitioners on how to approach regulated firms.

18/1/21

Completed.

Joint response with ShareSoc.

here

 

here

HMT

Review of UK Listing Rules.

5/1/21

Completed.  Joint response with ShareSoc.

here

here

 

FRC

FRC’s Draft Plan and Strategy and Budget 2021/ 2022.

12/3/21

Completed

Joint with ShareSoc.

here

here

IASB

Post Implementation Review of IFRS 10, 11 and 12.

10/5/21

Agreed not to respond.

here

N/A

FCA

Consultation on SPACs

28/5/21

Agreed not to respond.

here

 

IASB

Business Combinations under

Common Control.

1/9/21

Agreed not to respond.

here

 


NB. You can see the consultation response process followed by the Policy Team here.

Glossary

BEIS: the UK Government’s Department for Business, Energy and Industrial Strategy, currently with the tag line ”Building a stronger, greener future by fighting coronavirus, tackling climate change, unleashing innovation and making the UK a great place to work and do business.”

CRUF: The Corporate Reporting Users’ Forum, allows its global membership to learn about and respond to the many accounting and regulatory changes affecting corporate reporting.

ESG : environmental, social and governance is a generic term used in capital markets. used by investors to evaluate corporate behaviour  to determine the future financial performance of companies.”

FCA: the Financial Conduct Authority is the conduct regulator for 51,000 financial services firms and financial markets in the UK.

FRC: the Financial Reporting Council an independent regulator in the UK and Ireland, responsible for regulating auditors, accountants and actuaries, and setting the UK's Corporate Governance and Stewardship Codes.

IASB: the International Accounting Standards Board (IASB) is an independent, private-sector body that develops and approves International Financial Reporting Standards (IFRSs). The IASB operates under the oversight of the IFRS Foundation.

IFRS: International Financial Reporting Standards (IFRS) set common rules to make financial statements consistent, transparent, and comparable around the world.  IFRS are issued by the IASB.

IFRS Foundation: The IFRS Foundation is a not-for-profit international organisation responsible for developing the standards referred to as IFRS.

ISSB: the International Sustainability Standards Board is being established by the IFRS Foundation to provide ESG-related standards that are consistent, transparent, and comparable around the world. 

HMT: Her Majesty’s Treasury is the government’s economic and finance ministry controlling public spending and setting the direction of the UK’s economic policy.

TPR: The Pension Regulator protects the UK’s workplace pensions by ensuring employers, trustees, pension specialists and business advisers can fulfil their duties to scheme members.

UKEB: UK Endorsement Board influences, endorses and adopts new or amended international accounting standards issued by the IASB for use by UK companies.

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