Hogan Lovells 2024 Election Impact and Congressional Outlook Report
15 November 2024
At her inaugural Mansion House speech on 14 November 2024, the Chancellor of the Exchequer outlined a number of key policy initiatives for the UK financial services sector.
This is the first major announcement for the new government regarding its intentions for the financial sector. The message behind the proposals is that the government is looking to promote economic growth and that it sees the financial services sector playing a central part in that.
The main policy initiatives that were announced are set out below. More detailed commentary on some of the main initiatives will follow separately.
The Chancellor said that the UK has been regulating for risk, but not regulating for growth, and that it was time to take forward the next stage of reforms needed to drive growth, competitiveness and investment.
In that regard, the Chancellor has issued new growth-focussed remit letters to the FCA, the Bank of England’s Prudential_Regulation_Committee and Financial Policy Committee and both the FCA and the Payment Systems Regulator in relation to payments regulation.
Ahead of the Mansion House speech, the government had trailed its intention to reform the avenues for consumer redress, including to modernise the operations of the FOS and give consumers and firms more clarity.
In her speech, the Chancellor announced two developments relating to the FCA and the Financial Ombudsman Service (FOS):
In Spring 2025, the government will publish a Financial Services Growth and Competitiveness Strategy. The stated intention is to deliver long-term certainty and cement the sector’s place at the heart of the government’s 10-year modern Industrial Strategy.
A Call for Evidence has been published, to coincide with the Mansion Speech, which sets out the government’s thinking in more detail.
The government proposes focusing on five priority growth opportunities in financial services, namely: FinTech, sustainable finance, asset management and wholesale services, insurance and reinsurance, and capital markets.
The government suggests that an element of the strategy will be strengthening partnerships with established and fast-growing financial centres. The Chancellor also noted in her speech that she would be looking to reset the UK’s relationship with the EU.
The industry is invited to contribute to the development of the new Strategy, ahead of the Strategy’s publication next Spring.
The government launched a Pensions Investment Review in July 2024, and the Interim Report was published to coincide with the Mansion House speech. The interim report sets out the government’s plans, which will be legislated for in a Pension Scheme Bill in 2025.
The proposals include the following:
The government announced that it will introduce what it describes as “world first” trading venue for shares in private companies. The initiative, which is known as the Private Intermittent Securities and Capital Exchange System (PISCES), will allow secondary trading in securities already issued by private companies. These transfers will be exempt from stamp duty.
Following a consultation that closed in April 2024, the government has now published the Consultation Response, together with the draft legislation and an accompanying policy note. The Chancellor said that the legislation to establish the PISCES regime will be introduced in May 2025.
To coincide with the Mansion House speech, HM Treasury:
In addition, the government:
The government will be co-launching a Transition Finance Council alongside the City of London Corporation. This was one of the recommendations of the Transition Finance Market Review.
The government also announced that it will consult in the first half of 2025 on how best to take forward its manifesto commitment on transition plans in support of its ambition to become the global hub for transition finance - ensuring the UK’s regulatory framework is growth-focused, internationally competitive and maintains the UK’s status as a global financial hub.
The government has also emphasised the transition to net zero in the government’s economic strategy within the remit of the Bank of England’s Monetary Policy Committee, and reinstated sustainable finance as an area the Financial Policy Committee should support as part of its secondary objective.
To coincide with the Mansion House speech, the government published its National_Payments_Vision, which it describes as including decisive action to progress Open Banking and support fintech businesses.
The National Payments Vision responds to the findings of the independent Future of Payments Review 2023, which was led by Joe Garner.
In relation to insurance:
To support the mutuals sector, the government:
The government announced that it will be launching a pilot to delivering a digital gilt instrument (known as DIGIT), using distributed ledger technology.
The Chancellor said that some elements of the SMCR have become overly costly and administratively burdensome.
HM Treasury, the FCA and PRA will shortly publish the results of the review of the SMCR that it undertook following a discussion paper and Call for Evidence in 2023.
Among the matters that will be consulted on is the removal of the current Certification Regime. Under the current Certification Regime, staff below the senior management level must be certified by their firms not less than annually as being fit and proper to perform their roles. The intention is that this will be replaced with a more proportionate approach that reduces costs for financial services firms.
In October 2024, the PRA announced its intention to consult on reducing the current pay deferral periods that apply to certain senior managers at banks and building societies from seven years to five years. The Chancellor said that the government supports the PRA’s intention to consult on this issue.
HM Treasury announced its next steps for reforming the UK’s Markets in Financial Instruments Directive (MiFID) framework:
Authored by Dominic Hill.