David Trapp

Simmons & Simmons

David joined Simmons & Simmons in 2020 having trained and spent seven years qualified in the competition team of Freshfields in London.

David advises clients across all aspects of contentious and non-contentious EU and UK antitrust and competition law as well as national security and foreign investment regulation. His merger control work has included high profile UK and global transactions where he has managed the regulatory approval processes within the UK, the EU, and around the globe. His contentious work includes acting for clients subject to the European Commission interchange fee investigations as well as Competition and Markets Authority pharmaceutical probes.

David has experience of working within a broad range of industry sectors including financial services, retail and various consumer goods, technology media & telecommunications, energy and infrastructure.

David was called to the Bar of Lincoln’s Inn in 2008. In 2016 / 2017 David spent seven months on secondment to the CMA where he was part of the policy team, and in 2021/22 he spent seven months on secondment in the competition team of a multinational universal bank.

Practice Area

Financial Services

Panel

Contributing Author

Qualified Year

2013

Experience

Freshfields Bruckhaus Deringer LLP (August 2008 - March 2020)

Membership

Called to the bar of Lincoln’s Inn

Qualification

MA Geography and Psychology - 2006

Education

University of St Andrews (2002-2006)
Nottingham Law School (2006-2008)

1 Contributions by David Trapp

PRACTICE NOTES

FCA competition powers in UK financial services: concurrency with CMA, investigations, penalties, market studies, and the new secondary international competitiveness and growth objective (FSMA 2000/2023; DMCCA 2024).

Scope of this Practice Note This Practice Note sets out the Financial Conduct Authority’s (FCA’s) competition law powers under the Financial Services and Markets Act 2000 (FSMA 2000), together with associated investigative tools and sanctions for infringements. It also examines the secondary objective on international competitiveness and growth, introduced for the FCA and the Prudential Regulation Authority (PRA) by the Financial Services and Markets Act 2023 (FSMA 2023). In addition, it summarises the FCA’s programme of market studies, calls for input and other competition-focused reviews... Overview of the FCA’s competition law powers Under FSMA 2000, the FCA holds a statutory objective to foster effective competition for the benefit of consumers across markets for regulated financial services and for services supplied by a recognised investment exchange. When pursuing its other two statutory aims—protecting consumers and safeguarding market integrity—it must likewise further effective competition in consumers’ interests. Where markets appear to serve consumers poorly because competition is weak, the FCA may probe those markets and step in where necessary. These powers are confined to the firms and activities within its regulatory remit...

Financial Services

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