Julian Brown
Julian undertakes a broad range of financial services work, including the formation and regulation of collective investment schemes, regulatory work for fund management clients, and related company and commercial work.
His experience includes unit trust and open-ended investment company launches and complex reorganisations, detailed regulatory advice, financial promotion and custody issues, and offshore closed-ended fund projects. Julian has also been closely involved in the establishment of investment fund supermarkets and other related `multi-manager` external fund link arrangements.
Practice Area
Panel
- Contributing Author
1 Contributions by Julian Brown
PRACTICE NOTES
Implementing side pockets in FCA-authorised funds: emergency regime for Russia, Belarus and Ukraine sanctions-affected assets - scope, qualifying tests, governance, investor disclosures, costs and assessment of value under COLL
This Practice Note explains the Financial Conduct Authority (FCA) framework permitting authorised funds to deploy side pockets for assets hit by Russia’s invasion of Ukraine and the ensuing sanctions. It provides questions and answers on this framework, including topics such as:
scope
initial considerations
impact on investors
cost considerations
alternatives
changes to the FCA’s proposed rules
any further FCA guidance relating to side pockets and managing side pockets
It also highlights initial and ongoing considerations for establishing, operating, and managing side pockets within authorised funds effectively.
Background
On 6 July 2022, the Financial Conduct Authority (FCA) published policy statement PS22/8, ‘Protecting investors in authorised funds following the Russian invasion of Ukraine’, which outlined urgent measures to manage the invasion’s effects on authorised funds and retail investors. Those rules came into effect on 11 July 2022. That policy statement followed consultation paper CP22/8, ‘Protecting investors in authorised funds following the Russian invasion of Ukraine’, which invited views on the proposed emergency steps. The FCA recognises that the Russian invasion of Ukraine has had a significant impact on financial markets and on FCA-regulated authorised funds. To respond, the FCA is introducing an unprecedented liquidity management tool for authorised funds, called side pockets...
Financial Services
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