In response to today’s publication of key components of the UK implementation of the final Basel 3.1 standards agreed in December 2017, which will enter into force in the UK, in combination with the remaining elements anticipated for publication in the second quarter of 2024, Caroline Liesegang, Head of Prudential Regulation at the Association for Financial Markets in Europe (AFME), said:  “Implementing internationally agreed post-financial crisis reforms is an important step in maintaining the role of the UK as a leading international financial centre. Today’s publication of near-final policies on key elements of the Basel 3.1 package is a milestone in this regard, particularly for banks that play an important role in financing the real economy. The policies are closely aligned with international standards with some adjustments to improve risk measurement. “The adjustments include the recalibration of the alpha factor within the standardised approach for counterparty credit risk (SA-CCR). This limits any disproportionate increase in capital requirements for banks and the related impact on end-users' ability to access hedging products to mitigate their risks. “The PRA has also helpfully adjusted its approach in relation to the default risk of sovereign bonds by removing the inconsistency between the standardised approach and internal models. Under the PRA rules, banks are required to use the standardised approach for central government and central bank exposures. This approach should help in facilitating banks’ continued market making in UK government bond markets in support of the economy.  “However, there was scope for further improvements, for instance, through introducing greater differentiation in the treatment of regulated versus unregulated financial sector entities within the credit valuation adjustment framework. This would have recognised the lower risk of counterparties, such as insurance providers, that play a pivotal role in the real economy. Another example is the lack of recognition of insurance as a risk mitigant in the business indicator calculation in the operational risk framework - an approach that is inconsistent with other areas of the prudential framework and results in an overstatement of risk and disproportionate capital requirements.    “Nevertheless, we welcome the clarity brought through the publication of near final policies in these key policy areas and await the remaining elements: credit risk, the output floor, and reporting and disclosure requirements which will allow for the impact of the Basel 3.1 package to be assessed in its entirety.  “Additionally, we await the PRA’s planned review of the Pillar 2 framework to ensure there is no overlap with risks newly captured within the Pillar 1 framework as this will have a critical role in avoiding any undue increases in overall capital requirements.  “In the meantime, it will be important to ensure there is a coordinated timeline for implementing the package internationally, particularly as it relates to market risk standards. Developments in major jurisdictions should also be considered to ensure global consistency and to avoid harming the UK’s competitiveness.”  – Ends –

In response to the agreement reached by the European Parliament and the European Council on the CRR3 and CRD6 proposal, which will implement the final December 2017 Basel III rules in Europe and conclude an era of significant tightening of regulatory standards and constraints for credit institutions, Caroline Liesegang, Head of Prudential Regulation at the Association for Financial Markets in Europe (AFME), welcomed the agreement: “This agreement strengthens banks’ resilience and recognises their role in financing the economy. European banks have raised hundreds of billions in equity capital since the great financial crisis, resulting in record capital levels. This has resulted in greater stability in the financial system, effectively demonstrated earlier this year following some stress events in the banking system. AFME therefore calls on decision makers to resist further increases in capital requirements in the coming years as the banking sector goes through an important implementation phase and will need capacity to finance the real economy during the digital and green transition. “AFME in particular supports the agreement to maintain limited European market specificities while remaining faithful to the Basel principles. Improvements to the treatment of exposures to unrated corporates as the Output Floor is introduced are also welcome and should avoid unnecessarily restricting funding for corporates without ratings, which are key cogs in the EU economy. The recognition of the floor’s impact on securitisation and the introduction of a transitional arrangement to mitigate its impact is a positive development and will hopefully translate into the growth of the EU’s securitisation market. At the same time, a more extensive review of the capital treatment for the securitisation framework is important to ensure this tool can effectively be used by all banks, irrespective of their model approach, to finance the real economy. “Unfortunately, parts of the agreement lead to a suboptimal outcome for the European economy. AFME regrets that the Output Floor will be applied at the solo level of consolidation, despite the fact that it was calibrated by Basel to be applied at the highest level of consolidation. This is not in the interests of the competitiveness of the European banking market as it adds further market fragmentation. It is disappointing to see the lack of progress on market access which will inevitably have an adverse impact on the ability of EU financial institutions, corporates, governmental entities and individuals to access international markets and cross-border services. As further integration of the EU’s banking and capital market progresses, AFME hopes the EU will focus on addressing these obstacles to the free flow of capital and liquidity to allow for more efficient capital allocation in the EU. This will in turn benefit individuals, companies of all sizes and green/innovative projects. “As we look ahead at a long and complex implementation phase, it is important that the EU is flexible with regards to the implementation date, particularly with respect to market risk standards, to ensure global consistency and avoid harming its capital market competitiveness.” - ENDS -

The Association for Financial Markets in Europe (AFME) has today published a new report “Sustainable Finance in the EU: Priorities to unlock financing and investment”. The paper outlines AFME members’ views and recommendations on the functioning of the current EU sustainable finance framework, the implementation challenges that banks face in applying it to financing companies, and how its effectiveness could be improved. The paper then highlights AFME’s constructive recommendations for policymakers, including how policymakers and regulators can further enable financial institutions in providing financing in support of climate, environmental and social goals and provide a regulatory framework that helps to achieve this. Oliver Moullin, Managing Director of Sustainable Finance at AFME said: “Significant progress has been made in establishing the EU sustainable finance regulatory framework. A number of key areas of regulation now apply, with several more in the course of implementation. Nevertheless, the lack of clarity on policy to support the real economy transition combined with a number of significant challenges with the policy and regulatory framework are holding back the potential to further channel investments in support of sustainability objectives. “It is essential that the EU regulatory framework supports banks’ role in helping finance the transition and that it works in a way that supports the growth and competitiveness of the EU economy. It is time to take stock and consider targeted changes to enhance the coherence and effectiveness of regulation in achieving its objective. It is also critical to maintain focus on establishing roadmaps, reducing regulatory barriers and providing incentives for the real economy transition; and to provide greater emphasis on the important role of transition finance, recognising that financial institutions will need to provide finance to all parts of the economy throughout the transition.” AFME’s latest report highlights where financial institutions see challenges arising under the current regulatory framework, including: Lack of clarity on real economy transition and coherence with the sustainable finance regulatory framework; The availability of high quality data to support the use of sustainable finance tools and financial institutions’ own disclosure obligations; The usability and application of the EU taxonomy; The application of SFDR; Inconsistent treatment of derivatives in various disclosure metrics under the EU Taxonomy Regulation and SFDR; Alignment & coherence across the various ESG products disclosure regulations (e.g. SFDR, BMR, MIFID) Sequencing of the various reforms (e.g. SFDR, Taxonomy, BMR, Pillar 3) Concerns regarding potential allegations of greenwashing; Coherence and consistency of transition plans; and Challenges with international application and interoperability. The report sets out five priority recommendations to address identified challenges: Maintain focus on establishing roadmaps, reducing regulatory barriers for the deployment of sustainable investment projects and providing incentives for the real economy transition; Ensure that the regulatory framework is achieving its goals, is coherent and usable in practice to promote and support sustainable finance (including transition finance); Provide a stable regulatory framework with time for implementation and review how it is working in practice, with targeted guidance/changes introduced where needed in consultation with market participants; Ensure that regulation is promoting investment and does not adversely impact the competitiveness of financial institutions or companies operating in the EU and internationally; and Enhance international coordination and improve international interoperability with other key jurisdictions. Alongside recommendations on improving the functioning of the regulatory framework, the report also sets out recommendations in three further important areas which we see as priorities for EU policymakers: Facilitating transition finance; Developing carbon markets; and Scaling finance for nature. - ENDS -

Press releaseavailable inEnglish,French,German,Italian,Spanish Individual country analysis available forFrance,Germany,Italy,Spain The Association for Financial Markets in Europe (AFME) in collaboration with eleven other European and international organisations has today published the sixth edition of the “Capital Markets Union – Key Performance Indicators” report, tracking the progress of Europe’s capital markets against nine key performance indicators. This year’s report shows a mixed picture, revealing no discernible medium-term advancement on the CMU key performance indicators. This edition also coincides with the 30th anniversary of the Single Market. Here too, the data points show minimal change in the development of the EU's capital markets on a global scale. Adam Farkas, Chief Executive of AFME, said: “All the planned measures from the CMU Action Plan of 2020 have now been delivered by the Commission and EU leaders earlier this year committed to finalising negotiations on any open CMU issues before the next EU elections. However, certain goals, such as rebalancing the EU's funding sources toward more market-based financing, channelling individual savings into productive investments, and integrating national capital markets to create a unified EU market have not yet materialised to any meaningful degree. “It is clear that the financing structure of the EU economy will need to adapt, and at pace, if it is to support the EU’s significant and transformative investment needs, including the fast-approaching climate goals of 2030, as well as its demographic and competitiveness challenges. “Ahead of the next legislative cycle commencing, a strategic discussion on the best way forward will take place within the Eurogroup to set out recommendations for the next Commission. These recommendations are highly anticipated by the capital markets industry. The growth of an integrated capital market for Europe must continue to be a key priority if the European Union is to achieve its dual goals of sustainable and digital economic transformation.” Among the key findings of the 2023 report on European capital markets’ performance: Compared to last year’s numbers, there are slight improvements in some KPIs, mostly attributable to cyclical factors as 2022 was a particularly turbulent year for markets. When considering medium-term trends, it is clear that the EU has not made significant progress in developing its capital markets, particularly in terms of global competitiveness. While there are some slight improvements in some areas, these are mostly attributable to cyclical factors as 2022 was a particularly turbulent year for markets. Access to market-based finance for corporates has deteriorated, the amount of loans transformed into capital markets vehicles like securitisation has significantly declined, intra-EU integration has slightly deteriorated, while the amount of household savings in capital markets instruments has not shown any major progress. This calls for a closer look at the strategies being employed at EU level to deepen capital markets and a renewed focus on making real, lasting improvements that will have an impact going forward. EU competitiveness declines This year has seen a decline in the international competitiveness of the EU’s capital markets. AFME’s global competitiveness indicator shows the EU is still significantly behind the US and UK, particularly regarding access to finance, market liquidity, and digital finance capabilities. 30 years since establishment of Single Market,EU’s capital markets show no significant development, including on a global scale On 1 January 1993, the Single Market came into being. This year’s report provides a ‘snapshot’ of some key economic metrics to show how EU markets have developed over the past three decades. When viewed in this context, the data points are disappointing and there has been little change, including in a global context. For example, immediately before the creation of the Single Market, the current configuration of EU27 Member States accounted for 5% of global IPOs. In the first few years of the Single Market this rose to 20%. However, over the past three years, this figure was just 7% and the EU continues to be well below the annual flow of primary offerings observed in the US. Another bad year for EU IPOs IPO issuance fell 72% in H1 2023 compared to the same period last year. If current market trends persist, 2023 will be on track to have the lowest corporate IPO issuance volume since 2011. Appetite for market financing grows among corporates, but remains below historical levels In an EU business environment in need of diversification from over reliance on bank financing, there were positive signs of appetite for market financing increasing this year. In 2023, 10.3% of EU non-financial corporate funding was derived from capital markets sources, up from 7.8% in 2022 but substantially below the peak of 14.0% observed in 2021 and below 11.5% for 2016-2019, the years leading up to the pandemic.This was driven by a significant increase in bond issuance. End of cheap money era for SMEs as pre-IPO equity risk capital reverse Access to capital for SMEs has declined over the past 12 months. Early-stage funding, private equity and crowdfunding have all been affected. European households saw a decline in their savings in the form of capital markets instruments Savings levels grew substantially during the pandemic as spending was necessarily restricted, and many households put more of this money to work in capital markets. However, this effect is beginning to fade and, as inflation has risen sharply, our household investment indicator has declined to the lowest level since AFME’s first CMU report. The amount of savings in the form of capital market instruments stood at 90.4% of the EU’s GDP in 2023, falling from 91.4% in 2022. This is most likely due to people withdrawing from their savings to meet rising expenses. EU Securitisation issuance bounces back after a lacklustre 2022 This is predominantly thanks to a single large French RMBS deal (EUR 49.5 bn). If this deal is excluded, however, EU securitisation issuance would show a 15% decline. Over the last 10 years, annual securitisation issuance in the EU and UK has experienced muted growth. Adjusted by GDP, EU securitisation is strikingly low compared to other global economies. For example, in 2023, EU issuance was equal to just 0.3% of EU GDP, while UK issuance was equal to 0.7% of UK GDP, US issuance was at 1.1% of GDP, Australia at 2.6%, Japan at 1.4% and China at 1.5% of GDP. EU remains global leader in ESG bond origination ESG-labelled bond issuance in the EU represented 12.7% of total EU bond issuance in 2023. Issuers from other regions issued around 1% - 7% of bonds with ESG labelling, for example 7.1% (UK); 6% (Australia); 2.3% (China); 1% (US); 0.9% (Japan). EU fintech sector continued slowing down in 2023 Investment in Fintech saw a sharp decline in 2023 across regions compared to 2022. In the UK investment dropped by approx. 80%, followed by the EU where investment decreased by 78%. The US saw roughly 65% less investment in 2023 Fintech Unicorn valuations decreased across regions. In the EU the cumulative value of Unicorns decreased 20%. In the UK the valuation reduced 15%. – Ends –

AFME has responded to the European Commission’s consultation on a legislative proposal to open up access to financial data (FIDA proposal). James Kemp, Managing Director at the Association for Financial Markets in Europe (AFME), said: “We support the EU’s ambition to create a consumer-centric data-sharing ecosystem. To achieve this, policies such as the new EU Open Finance framework need to contribute to a fair and secure data ecosystem that adds value to consumers and end users. In order for the proposal to bring the full suite of benefits to the EU financial data ecosystem, some key changes are required – for example sufficiently regulating the new category of data users (‘Financial Information Services Providers’) and facilitating reasonable compensation that enables investments in secure and innovative data markets.” Among the key points from AFME’s consultation response are: Trust is key to building a data-sharing ecosystem. Building such trust requires secure data-sharing infrastructure and safeguards around the use of data. To ensure data is used correctly and securely, the Open Finance framework needs to uphold the digital operational resilience, cybersecurity and data protection standards currently applied to financial institutions. We remain concerned that the new category of data users (‘Financial Information Service Providers’) could become a weak link in the financial system if they are not adequately regulated and supervised to the same high standards. To maintain a fair and level playing field in data sharing across sectors, BigTech gatekeepers should not be allowed to authorise as Financial Information Service Providers and use data held by financial institutions under Open Finance until sharing of data by these companies has been effectively implemented under the Digital Markets Act. To preserve the ability and create the incentives for data holders to make adequate investments in secure data-sharing infrastructure, it is key that reasonable compensation be included in regulation, including the Payment Services Regulation. Compensation should be set in a way that enables access for all participants. For small and micro data users, we believe compensation should be capped at cost, whereas mid-sized and larger companies that use data should be required to pay a reasonable and market-led compensation to data holders for investing in secure data-sharing infrastructure. The greatest potential added value exists for retail consumers. Open Finance should therefore only be applied to individuals and SMEs. Moreover, data-sharing policies like Open Finance should not discourage banks and others from investing in data-driven customer services. Due to potential infringement on trade secrets and intellectual property, proprietary and inferred data should be kept out of scope. We also support data sharing without unduly delay, but real-time data sharing is disproportionately burdensome and does not yield commensurate benefits. Due to the complexity of scheme development and the technical build required, we support an implementation period of at least 36 months for the schemes, followed by at least 12 months for the rest of FiDA. This should begin with a phased approach that prioritises targeted use cases identified as delivering the most significant benefits and requiring limited development, also to facilitate a more balanced and pragmatic decision-making process with regards to the governance of the data sharing schemes. - ENDS -

The Association for Financial Markets in Europe (AFME) has appointed Rémi Kireche as Director of Advocacy to help drive forward the Association’s advocacy on Capital Markets Union (CMU), including in the policy areas of securitisation, equity capital markets, post-trade and sustainable finance, among others. Rémi has spent 10 years working in financial services and public affairs in Brussels and Paris. He joins AFME from Flint Global, a political risk consulting firm where he advised financial institution clients on EU financial services policy and regulation. Prior to Flint Global, Rémi worked for more than 5 years at the European Commission in the Directorate General for Justice and Consumers. Rémi has also worked directly within financial institutions, having worked at one of AFME’s Board Member Firms, Société Générale, as a European Affairs Adviser. Prior to this he worked for the French regulator, the Autorité des marchés financiers (AMF), as a European Policy Officer, providing analysis and briefings on the activities and proposals of EU Institutions relevant to the AMF’s mandate, such as CMU. In 2013, Rémi also worked in Michel Barnier’s cabinet when he was the European Commissioner for the Internal Market. Jacqueline Mills, Managing Director, Head of Advocacy, said: “We are delighted to appoint Rémi as a Director in AFME’s Advocacy team, joining us in Brussels to lead our work promoting capital markets which support economic growth across the EU and the UK. Rémi joins at a strategically important moment as the European Institutions begin to reflect on which actions to take forward in the next policy cycle to ensure that capital markets have the scale and depth needed to support investors and issuers. Rémi brings a wealth of experience in financial services policy from both the public and private sectors and we look forward to working with him.” – Ends –

The Association for Financial Markets in Europe (AFME) welcomes the first meeting of the EU-UK forum for regulatory cooperation, which took place on 19 October. Adam Farkas, Chief Executive of AFME, said: “The inaugural meeting of the Forum presents a unique opportunity to lay the ground for a cooperative, stable, and trusting long-term relationship by ensuring structured dialogue on both jurisdictions’ regulatory initiatives and priorities.” “The Forum should be designed to facilitate exchange of information on the functioning of regulatory frameworks as well as on key regulatory developments for financial services and their implementation. The Forum should also provide a platform to allow both jurisdictions to identify and share concerns related to any emerging risks to financial stability. It should also form the basis for cooperation on common challenges such as climate change and the digital transition. Ideally, a strong bilateral regulatory dialogue should comprise both structured discussion and ongoing informal dialogue at working level, and we hope that the meetings of the Forum will allow for cooperation to intensify at all levels.” – Ends –

In response to a Call for Evidence on shortening settlement cycles in the EU, published by ESMA today, Pete Tomlison, Director of Post Trade at the Association for Financial Markets in Europe (AFME), said: “This Call for Evidence is an important step in moving forward the debate on T+1 settlement. Moving to T+1 should not only be a question of “when”, but also “why” and “how”. It is important to ensure that any decision to shorten the settlement cycle is underpinned by a robust qualitative and quantitative analysis of the potential benefits, risks and costs, and also takes account of the unique complexities of EU capital markets. Any potential move to T+1 will require collaboration from a broad range of industry stakeholders, with the ultimate objective of making EU securities markets safer and more efficient. We welcome the opportunity to contribute to this initiative.” – Ends – Notes to Editors: AFME is leading the European Task Force in preparation for the move to T+1 settlement cycles. Our current areas of focus are: Helping members prepare for the US move to T+1 in 2024 Participating actively in the UK Accelerated Settlement Task Force Leading the collaboration with other EU stakeholders to present a common view back to EU authorities Preparing a report on what the industry can do now to address the high level of settlement fails, and prepare the ground for T+1

Today, the Association for Financial Markets in Europe (AFME) has submitted its response to the Financial Conduct Authority’s (FCA) consultation paper CP23/15: The Framework for a UK Consolidated Tape. AFME’s response outlines members’ views on the framework that the FCA has proposed for the UK bonds consolidated tape and includes commentary on the UK equities consolidated tape, for which a dedicated consultation paper is expected in 2024. AFME welcomes the FCA’s initiative to embed the framework that will encourage the development of a consolidated tape in the UK. Members’ response to this consultation reflects the broad industry consensus that a resilient, cost-effective consolidated tape providing timely, good quality data will facilitate greater access to a common view of the UK market to all investors, irrespective of resources and level of sophistication. This comprehensive and standardised view of equities and fixed income trading environments will enhance the global competitiveness of UK wholesale markets. Victoria Webster, Managing Director of Fixed Income at AFME, said: “The establishment of a consolidated tape for bonds in the UK is a major milestone. The UK has a leading global market and it is vital to ensure that it remains competitive by widening access to market data and broadening participation in capital markets from investors, both domestically and internationally. “At the same time, even an appropriately constructed consolidated tape will not fully address the current unacceptably high cost of market data. We trust that the FCA’s extensive work on wholesale data will help address anomalies in this area, which are detrimental to financial markets and their users.” While there are many aspects to consider around the establishment of a consolidated tape AFME views the following as most pressing: Licensing – The CT should be sold under a simple, single market data licensing framework covering a variety of use cases and clearly specifying what is deemed re-use and what is considered direct use of data. A standardised CT user licence would remove disincentives to access data via an authorised CTP, arising from managing multiple licenses with differing terms and policies. Tender process - Price should not be the only determinant in the second stage bidding process. A CTP may have included features that are more useful for the market but their overall offering may not be the cheapest. It is important that a balance is found between operational capacity and the price charged. Governance – A consultative committee representative across a range of users and data producers, with a rotation of its members, should meet regularly to advise and suggest recommendations to the CTP. Operating costs - The cost of operating the CT should be aligned with keeping the cost of accessing the CT as low as possible for users. A key benefit of the CT is the potential to facilitate market data access to market participants who currently cannot access these feeds. Furthermore, information on operating costs should be transparent to and regularly shared with the consultative committee. Pre-trade data for the equities tape - A well-functioning, commercially viable equities CT requires pre-trade data from the outset. This data, including both price (best bids and best offers) and size, should be real-time, continuous, and available to five levels of book depth in total with full attribution (identifying the venue). An equities CT with these features would be highly valuable to market participants and would perform well in comparison to equivalent mechanisms in other jurisdictions. AFME looks forward to making further progress on this initiative with the FCA and other industry partners. – Ends –

The Association for Financial Markets in Europe (AFME) has submitted its response to the EU Commission “Have your say” consultation on the EU Retail Investment Strategy, raising member concerns about the overly prescriptive nature of the proposals. Adam Farkas, CEO of the Association for Financial Markets in Europe (AFME) commented: “AFME strongly supports the Commission’s objective of making the distribution of securities to European retail investors more efficient. We also support the Commission’s ambition to significantly raise the percentage of European retail investors’ direct and indirect participation in EU capital markets. However, in view of the fact that a significant number of investment products distributed to retail investors are sourced and manufactured by wholesale banks, asset managers and insurers, AFME is concerned by the many ways that the Retail Investment Strategy (RIS) could impact wholesale capital markets, as well as the availability of investment product for retail investors, reducing rather than enhancing their choice. AFME believes that alternative approaches, including those used in other jurisdictions, should continue to be carefully explored based on their success to ensure the effectiveness of the proposals.” In particular, AFME notes the following 4 areas of the proposals: Value for Money AFME supports the Commission’s ambition to provide fair value to retail investors. However, the proposed prescriptive benchmark-based approach is problematic in terms of achieving consistency and accuracy for any such benchmark to give a fair indication of cost and/or performance. The value of a product/investment to a particular investor depends on many factors, such as quality of service or sustainability features, which is inherently subjective and differs between clients. Additionally, this heavily quantitative-based approach could result in some investors receiving products that do not offer value for money because the benchmark overlooks other relevant factors. AFME believes it would be more effective to either pursue a more qualitative, outcomes-based approach or an approach facilitating flexibility between quantitative and qualitative factors. Best Interest AFME does not see a compelling rationale to revise existing Best Interest requirements in the MiFID inducements rules. The Commission’s proposals on Best Interest impose a significant burden on firms and seem to be duplicative of the value for money proposals. The new criteria takes an approach towards investment advice that is mostly focused on costs, and does not consider other key parameters that are important in the context of investment advice, such as best interests, since many products with higher fees could potentially also deliver a better overall return to particular investors best suited for those types of products. This approach risks “downgrading” the value of the investment advice as a whole. The new criteria may also result in advisers steering retail clients only towards the lowest cost products (e.g. sovereign bonds, certain categories of shares, or passive investment funds), which may not always lead to best investment results for retail clients who may be looking for best overall returns over the long term. Inducements It is helpful that the Commission has not applied the inducements ban to advised distribution models. However, with respect to the inducements ban for non-advised services pertaining to packaged retail and insurance-based investment products(PRIIPs), the scope and rules require further adjustments to ensure that they do not cast the net wider than is required to meet the Commission’s stated objective in this area. In addition, AFME is of the view that the post RIS-review should occur five years (not three years) after the RIS amendments have become fully operational. The review should also look at the whole package (rather than the inducement changes in isolation). AFME also suggests clear criteria should be set for the review, including explaining how it will measure the effectiveness of the revised inducement provisions in managing conflicts of interest and considering other factors, such as consumer outcomes and the supply of products for different investor requirements. Client Categorisation AFME welcomes measures to enable more sophisticated and experienced retail investors to ‘opt up’ to professional client status. This can facilitate a broader range of investment opportunities to a wider range of clients which may result, overall, in an increase of capital being made available to issuers in EU capital markets. To achieve this, the standards which will specify the ‘opt up’ criteria must be clearer in scope and on the evidence required to demonstrate financial expertise. – Ends –