Financial Services Regulatory Update – October 2023 Round Up
| ESG/Sustainability | |
|---|---|
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Council of the EU adopts Green Bond Regulation |
On 23 October 2023, the Council of the EU adopted a Regulation (adopted text here) creating a new voluntary “European green bond” or “EuGB” label, which can be used to market environmentally sustainable bonds that align with the EU’s Taxonomy Regulation. Issuers who choose to market their bonds as “European green bonds” will be subject to uniform requirements that aim to harmonise the EU market for green bonds, and ensure that investors can more confidently direct funds towards financial products that align with their sustainability preferences. The Regulation awaits publication in the EU’s Official Journal, and will start applying 12 months after entry into force. A transition period will apply for the first 18 months of application. |
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Proposed Delay in Adoption of Sector-Specific ESRS |
On 17 October 2023, the European Commission published a draft proposal (here) delaying the date of adoption of the sector-specific European sustainability reporting standards (“ESRS”) by two years, from 30 June 2024 to 30 June 2026. According to the European Commission, the proposed delay would allow in-scope companies to focus on implementing the first set of ESRS, which were adopted on 31 July 2023 (see our briefing here). It would also ensure that the European Financial Reporting Advisory Group (“EFRAG”) has enough time to develop sector-specific ESRS that are efficient, and that limit the reporting burden on companies. |
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Integration of ESG-related Risks in Prudential Frameworks |
On 12 October 2023, the European Banking Authority (“EBA”) published a report (here) on the role of ESG-related risks in the prudential framework of credit institutions and investment firms. Employing a risk-based approach, the EBA’s report assesses how the current prudential framework captures ESG-related risks. The report recommends enhancements to accelerate the integration of ESG-related risks across the Pillar 1 framework. The proposed enhancements aim to support the transition to a more sustainable economy, whilst ensuring the continued resilience of the banking sector. |
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Stakeholder Request Mechanism relating to the EU Taxonomy |
On 17 October 2023, the Platform for Sustainable Finance, together with the European Commission, launched a stakeholder request mechanism (here) relating to the EU taxonomy for sustainable activities. The stakeholder request mechanism allows stakeholders to submit suggestions based on scientific and/or technical evidence on new economic activities that could be added to the EU taxonomy, or on potential revisions of technical screening criteria of existing activities. The stakeholder request mechanism will run continuously, allowing respondents to submit their input at any given time. On 15 December 2023, all requests will be processed by the platform’s technical working group. After 15 December, the tool will continue to run, and a second cut-off-date will be communicated. |
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Commission Notices regarding the EU Taxonomy |
On 20 October 2023, the following notices of the European Commission were published in the Official Journal, containing responses to FAQs relating to the Taxonomy Climate Delegated Act and the Disclosures Delegated Act under the EU’s Taxonomy Regulation:
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ECON Report on Proposed EU Regulation on ESG Rating Activities |
The European Parliament’s Economic and Monetary Affairs Committee (“ECON”) has published a draft report (here), dated 6 October 2023, on the proposed EU Regulation on the transparency and integrity of ESG rating activities. According to the Rapporteur’s statement, whilst the proposed changes may seem technical, they are “essential” to ensure reliability and transparency in the ESG ratings market, and to guarantee the availability of meaningful ESG data. |
| Capital Requirements/Credit Institutions | |
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Council of the EU adopts Revised Consumer Credit Directive |
On 9 October 2023, the Council of the EU announced via a press release (here) that it has formally adopted the revised Consumer Credit Directive (the “CCD II”). The revised Directive was published in the EU’s Official Journal on 30 October 2023 (here) and awaits entry into force. The revised CCD, which will repeal and replace Directive 2008/48/EC following the date of application of 20 November 2026, is considerably broader in scope, compared to its precursor. According to the Council of the EU, the revised Directive:
After entry into force, EU Member States will have two years to adopt necessary laws and administrative provisions, in order to transpose the Directive, and a year after that in which to apply them. |
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RTS on Risk Retention Requirements under the Securitisation Regulation |
On 18 October 2023, Delegated Regulation (EU) 2023/2175 (here), containing regulatory technical standards (“RTS”) under the Securitisation Regulation on risk retention requirements for originators, sponsors, original lenders and servicers, was published in the EU’s Official Journal. The Delegated Regulation will enter into force on the twentieth day following that of its publication. |
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RTS on the Calculation of a Stress Scenario Risk Measure |
On 20 October 2023, the European Commission adopted a Delegated Regulation (here) containing RTS on the calculation of the stress scenario risk measure under Article 325bk(3) of the Capital Requirements Regulation (“CRR”), as amended by CRR II. |
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European Supervisory Examination Programme for 2024 |
On 19 October 2023, the EBA published the European Supervisory Examination Programme (“ESEP”) for 2024 (here), setting out key topics for heightened supervisory attention. Key areas of focus for 2024 include: (i) liquidity and funding risk; (ii) interest rate risk and hedging; and (iii) recovery operationalisation. |
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ECON Reports on CMDI Reform Proposals |
On 5 October 2023, ECON published the following draft reports relating to proposed reforms concerning the EU’s bank crisis management and deposit insurance (“CMDI”) framework:
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BCBS Report on Recent Bank Failures |
On 5 October 2023, the Basel Committee on Banking Supervision (“BCBS”) published a report (here) on the banking turmoil experienced during 2023, which includes the failures of major US banks, and the rescue of Credit Suisse (by means of its acquisition by UBS). The report provides an assessment of the factors behind the crisis, and outlines the regulatory and supervisory responses, and initial lessons learnt. According to the BCBS, the turmoil experienced during 2023 is the most significant system-wide banking stress, in terms of scale and scope, experienced since the financial crisis of 2008. The bank failures, which largely had distinct causes, triggered a broader crisis of confidence in the resilience of banks, banking systems and financial markets across multiple jurisdictions. In response, wide-scale public support measures were deployed by some jurisdictions to mitigate the impacts of the stress. On 10 October 2023, the Financial Stability Board (“FSB”) published a similar report (here), outlining the preliminary lessons of the crisis, from a bank resolution standpoint. |
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ECB Report on Counterparty Credit Risk Management |
On 20 October 2023, the European Central Bank (“ECB”) published a final report (here) on sound practices for counterparty credit risk governance and management, following a public consultation which ran until July 2023. The report presents the findings of the targeted review performed during H2 2022 on how banks govern and manage counterparty credit risk. It highlights sound practices observed in the market and points to areas where improvements are required. Institutions are expected to consider the contents of the report when formulating approaches to credit risk management. The ECB has additionally published a feedback statement (here) in respect of its public consultation. |
| Insurance / Insurance Distribution | |
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Reduction in Motor Insurers Insolvency Compensation Fund Levy |
On 25 October 2023, the Minister for Finance and the Minister of State for Financial Services, Insurance and Credit Unions issued a joint press release (here) welcoming the signature of a statutory order (here) reducing the Motor Insurers Insolvency Compensation Fund (“MIICF”) levy from 2% to 1%. According to Minister of State Jennifer Carroll MacNeill, Government-driven insurance reforms have created opportunities for new entrants and incumbent insurers to expand their risk appetites, and to provide more competitive choices for consumers. The reduction in the levy will benefit policy holders on renewal from 1 January 2024. |
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EIOPA’s Strategy for Digital Transformation |
On 12 October 2023, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a document (here) outlining its digital strategy and approach to digital transformation for the period 2023-2026. EIOPA has identified three key long-term priority areas:
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EIOPA Consultation on the Supervision of Captive (Re)Insurance Undertakings |
On 6 October 2023, EIOPA launched a public consultation (here) on its draft opinion (here), delivered on the basis of the Solvency II Directive, regarding the supervision of captive (re)insurance undertakings, with a particular focus on intra-group transactions, the prudent person principle and governance. The draft opinion is addressed to competent authorities and outlines the supervisory expectations while taking into account the specificities of a captive (re)insurer’s business model. Stakeholders can submit feedback on EIOPA’s consultation until 5 January 2024. |
| Investment Firms / MiFID | |
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ESMA to launch CSA on Integration of Sustainability Requirements |
On 3 October 2023, the European Securities and Markets Authority (“ESMA”) announced (here) that it will launch a common supervisory action (“CSA”), to run in 2024, with national competent authorities on the integration of sustainability in firms’ suitability assessment and product governance processes and procedures, in accordance with related amendments to delegated acts under the Markets in Financial Instruments Directive (“MiFID II”). The CSA will address the following:
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Proposed Amendments to MiFID II/MiFIR |
The Council of the EU has published notices, dated 13 October 2023, setting out the final compromise texts in respect of the proposals to amend: (i) MiFID II (proposed amending Directive here); and (ii) the Markets in Financial Instruments Regulation (“MiFIR”) (proposed amending Regulation here). The proposed amending texts would bring changes to the MiFID II/MiFIR regime in respect of data quality standards and data transparency, removing obstacles to the emergence of consolidated tapes, banning payments for order flows, and optimising trading obligations. A full summary of changes proposed is available in the European Parliament’s “EU Legislation in Progress” briefing (here). The Council of the EU has also issued a communication (here), dated 18 October 2023, confirming that the Permanent Representatives’ Committee has endorsed both texts. In the communication, the Chair of the Permanent Representatives’ Committee confirms that, should the European Parliament adopt its position at first reading in the form set out in the compromise package, the Council would approve the European Parliament’s position. During its meeting on 24 October 2023 (here), ECON members endorsed the amending texts; they now await final approval by the European Parliament and the Council of the EU. |
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ESMA Briefing on Circuit Breaker Calibration |
On 12 October 2023, ESMA published a supervisory briefing (here) setting out its expectations in respect of the implementation of circuit breakers pursuant to the provisions of MiFID II. ESMA explains the circuit breakers are used by trading venues to guard against market volatility, and has developed its briefing to promote supervisory convergence on the calibration of circuit breakers. |
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ECON Reports on Proposed Reform of Retail Investor Protection Framework |
On 2 October 2023, ECON published draft reports on:
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| Investment Funds | |
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CBI Consultation on ELTIF 2.0 |
The Central Bank of Ireland (“CBI”) has launched a consultation (here) on amendments to the regulatory framework for European long-term investment funds (“ELTIF”) framework, also known as “ELTIF 2.0”. The CBI’s consultation paper confirms that it intends to include a new chapter dedicated to ELTIFs in the AIF Rulebook. The CBI’s consultation process will run until 13 December 2023. For more information, please see our briefing (here). |
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CBI Response to Department of Finance’s Funds Sector Review |
On 17 October 2023, the CBI published its response (here) to the Department of Finance’s review of the Irish funds sector (Funds Sector 2030). In its response, the CBI outlines its perspective on the evolution of the Irish funds sector, with a view to ensuring that the sector is resilient, and that it delivers value for investors, and to the Irish and EU economies. The CBI offers support for the aims of the Department of Finance’s review, and sets out five priority areas that it believes will be critical to the future development of the Irish funds sector. Areas identified relate to the following: (i) delivering positive outcomes for the domestic economy and investors; (ii) developing a macroprudential framework for investment funds; (iii) maintaining regulatory effectiveness; (iv) sustainable finance; and (v) digital transformation. |
| EMIR | |
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ESRB Letter concerning Proposed Inclusion of Active Account Requirement in EMIR 3.0 |
The European Systemic Risk Board (“ESRB”) has published a letter (here), dated 4 October 2023, in which it outlines its continued support for the introduction of an active account requirement ("AAR") as part of the proposal, known as “EMIR 3.0”, to amend the European Market Infrastructure Regulation (“EMIR”) as regards the exposure of EU clearing markets to third-country central counterparties (“TC-CCPs”). Several European and international trade associations recently issued a joint statement (here) that was highly critical of the proposed inclusion of the AAR. For more information on the EMIR amendment process, please see our briefing (here). |
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ESMA Guidelines for Reporting under EMIR |
On 23 October 2023, ESMA published guidelines (here) for reporting under EMIR. The guidelines will apply from 29 April 2024 in relation to the derivatives reporting obligation under Article 9 of EMIR and trade repositories’ (“TRs’”) obligations under Articles 78 and 81. |
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Implementing Decision concerning Equivalence of Australian Financial Markets |
On 13 October 2023, the European Commission adopted an Implementing Decision (here) amending Implementing Decision (EU) 2016/2272 on the equivalence of financial markets in Australia in accordance with EMIR. Since adoption of the preceding Implementing Decision, an additional financial market established in Australia has obtained authorisation from the Australian Securities and Investments Commission (“ASIC”) to trade in derivatives, and the EU framework has now been amended accordingly, noting that the additional financial market complies with legally binding requirements equivalent to those contained under MiFID II. |
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RTS Reflecting Transition to TONA and SOFR Benchmarks |
On 11 October 2023, the European Commission adopted a Delegated Regulation (here), under EMIR, containing RTS drafted to reflect transitions to certain benchmarks referenced in certain OTC derivative contracts, namely the Tokyo Overnight Average Rate (“TONA”) and the Secured Overnight Financing Rate (“SOFR”), in the wake of the cessation of USD LIBOR. The Delegated Regulation awaits publication in the EU’s Official Journal. |
| Central Counterparties | |
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Extension of Temporary Measures regarding CCP Collateral Requirements |
On 13 October 2023, ESMA announced via a press release (here) that it has extended, for a limited period of six months (until 29 May 2024), emergency measures that temporarily expand the pool of eligible collateral for all types of counterparties. Uncollateralised bank guarantees for non-financial counterparties (“NFCs”) acting as clearing members, and public guarantees for all types of counterparties, will continue to be temporarily eligible, in order to avoid potential disruption over the coming winter months. The temporary measures were first adopted during the height of the energy crisis to alleviate the liquidity pressure on NFCs active in regulated gas and electricity markets that clear in EU-based CCPs. ESMA’s final report (here) has been sent to the European Commission for endorsement and will be subject to a scrutiny procedure by the European Parliament and the Council of the EU. |
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ESMA Consultation on Fees Charged to Third-Country CCPs |
On 12 October 2023, ESMA launched a public consultation (here) on proposed revisions to the Delegated Regulation regarding annual fees charged to Tier 1 TC-CCPs under EMIR. ESMA’s proposals aim to ensure that the annual fees charged to Tier 1 TC-CCPs are proportionate and accurately reflect differences in size and activity across Tier 1 TC-CCPs. ESMA’s consultation runs until 10 November 2023. |
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ESMA Opinion on CCP Back-Testing Requirements |
On 16 October 2023, ESMA published an opinion (here) on CCP back-testing requirements pursuant to Article 49 of EMIR and to Delegated Regulation (EU) 153/2013. ESMA’s opinion seeks to clarify CCP back-testing practices under EMIR, and in particular where back-testing is performed for the purpose of core model back-testing for model validation or margin adequacy back-testing. The opinion aims to harmonise practices across authorised EU CCPs, but does not intend to limit CCPs' freedom of modelling, nor prescribe a specific margin model. |
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RTS on Business Reorganisation Plans |
On 26 October 2023, the European Commission adopted a Delegated Regulation (here) RTS supplementing the Regulation on a framework for the recovery and resolution of central counterparties (the “CCP Recovery and Resolution Regulation” or “CCPRRR”) with regard to the minimum elements to be included in a business reorganisation plan and the criteria to be fulfilled for its approval by a resolution authority. |
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ESAs’ Board of Appeal suspends ESMA Decision concerning Third-Country CCP |
On 25 October 2023, the Joint Board of Appeal of the European Supervisory Authorities (“ESAs”) published a decision (here) suspending a decision of ESMA to withdraw recognition of a UAE-based third-country central counterparty (“TC-CCP”), following the UAE’s inclusion on the European Commission’s list of high-risk third countries with regard to money laundering (“ML”) and terrorist financing (“TF”). ESMA’s withdrawal decision concerning Dubai Commodities Clearing Corporation (DCCC) is suspended until the outcome of the appeal against ESMA’s decision. |
| Securities | |
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ESMA consults on Impact of Shortening EU Settlement Cycle |
On 5 October 2023, ESMA published a call for evidence (here) on the potential impacts of shortening the EU’s settlement cycle. The call for evidence will help ESMA assess the costs and benefits of a possible shortening of the settlement cycle, and identify whether any regulatory action is needed to mitigate any negative impacts that could arise for EU market participants. In particular, ESMA invites market infrastructures (CCPs, central securities depositories, trading venues), their members and participants, other investment firms, issuers, fund managers, retail and wholesale investors, and their representatives, to provide detailed feedback on the questions put forward for consultation. Submissions can be made until 15 December 2023. |
| Fintech/Digitalisation | |
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Digital Euro Project moves to Preparation Phase |
On 18 October 2023, the ECB announced (here) the decision of its Governing Council to continue work on the digital euro project by moving to the preparation phase of its exploratory exercise, without yet taking a decision in respect of actual issuance. A report has been published (here) summarising the key findings of the investigation phase, which has now concluded. Building on the findings of the investigation phase, the preparation phase will focus on further preparing for the development of a digital euro; it will begin in November 2023. |
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Council of the EU adopts Directive on Distance Financial Services Contracts |
On 23 October 2023, the Council of the EU announced via a press release (here) that it has adopted a Directive concerning financial services contracts concluded at a distance. The adopted Directive (adopted text here) revises the current legal framework for distance financial services contracts in the context of rapid technological development in the market. According to the EU, the Directive will boost online consumer protection and provide traders with legal clarity. The Directive would serve as a “safety net”, meaning that all financial services not covered by specific sectoral legislation would be covered by the new rules. The adopted Directive awaits publication in the EU’s Official Journal. After entry into force, EU Member States will have 24 months to transpose its provisions into national law, and a further six months in which to apply them. |
| AML/CFT | |
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EU Briefing on AML Measures in National Recovery and Resilience Plans |
On 9 October 2023, the European Parliament published a briefing (here) on AML measures contained in EU Member States’ national recovery and resilience plans (“NRRPs”), including in Ireland’s NRRP (here). The briefing contains three milestones and one target with regard to AML reform. The target, set for completion in mid-2023, seeks to increase the number of inspections of trust and company service providers (“TCSPs”) to at least 120, as well as build capacity in the AML compliance unit. The milestones refer to the review of the regulatory enforcement toolkit under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, and the publication of a sectoral risk assessment relating to TCSPs. |
| Payments | |
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FSB Report on KPIs relating to Cross-Border Payments |
On 9 October 2023, the FSB published its inaugural annual report (here) in respect of the key performance indicators (“KPIs”) formulated in 2021 to measure the extent to which targets are being achieved in relation to delivering cross-border payments that are cheaper, faster, transparent and more accessible, pursuant to the G20’s roadmap for enhancing cross-border payments (here). |
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CPMI Reports on Cross-Border Payments |
On 17 October 2023, the Committee on Payments and Market Infrastructures (“CPMI”) of the Bank for International Settlements (“BIS”) published a report (here) to the Indian G20 Presidency in relation to harmonised ISO 20022 data requirements for the enhanced processing of cross-border payments. ISO 20022 is an international standard for exchanging electronic messages between financial institutions which, according to the CPMI, has the potential to allow more consistent and structured data in payment processing. To this end, the proposed harmonisation requirements provide payment system operators and participants with guidance on how to implement ISO 20022 in a consistent manner to help facilitate faster, cheaper, more accessible, and transparent cross-border payments. The CPMI recommends that payment system operators and participants begin preparations to align their ISO 20022 usage guidelines with these harmonisation requirements ahead of the target date for implementation of end-2027. The CPMI has additionally published a report (here) on governance and oversight considerations relating to cross-border payment system interlinking arrangements. |
| Benchmarks | |
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Final Extension of Transition Period for Third-Country Benchmarks |
On 23 October 2023, a Delegated Regulation (here) extending the transition period for use of third-country benchmarks in the EU, in accordance with Article 51(5) of the Benchmarks Regulation (“BMR”), was published in the EU’s Official Journal. The transition period will now run until the revised deadline of 31 December 2025. For more information, please see our recently-published briefing (here). |
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European Commission adopts Proposal amending BMR |
On 17 October 2023, the European Commission published the proposal it has adopted (here) for a Regulation amending the BMR as regards the scope of the rules for benchmarks, the use in the EU of benchmarks provided by an administrator located in a third country, and certain reporting requirements. The proposal makes targeted amendments seeking to improve how the BMR functions, and is part of a package of measures that aim to streamline authorisation and registration processes to alleviate the regulatory reporting burden on EU companies, particularly for SMEs. Subject to the legislative process, the aim is for the revised BMR regime to come into force on 1 January 2026, following the expiry of the extended transition period for the use of third-country benchmarks. |
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RTS Reflecting Transition to TONA and SOFR Benchmarks |
The European Commission has adopted a Delegated Regulation (here) containing RTS drafted to reflect transitions to benchmarks referenced in certain OTC derivative contracts, namely TONA and SOFR, in the wake of the cessation of USD LIBOR. See EMIR above |
| Crypto-Assets | |
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ESMA clarifies Timeline for MiCA Implementation |
On 17 October 2023, ESMA published a statement (here) offering clarification on the timeline for implementation of the Markets in Crypto-Assets (“MiCA”) Regulation, and encouraging market participants to begin transition preparations. ESMA stresses that MiCA rules on the provision of crypto-asset services will not enter into full application until December 2024. As such, holders of crypto-assets and clients of crypto-asset service providers (“CASPs”) will not benefit, until then, from any EU-level regulatory and supervisory safeguards, or from recourse mechanisms built into the MiCA Regulation. |
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Consultations on Draft RTS and Draft Guidelines under MiCA |
The EBA has launched consultations, running until 22 January 2024, relating to the following draft RTS and draft guidelines issued under the MiCA Regulation:
The EBA has additionally, together with ESMA, launched a consultation (here), which runs until 22 January 2024, on a set of draft joint guidelines on the suitability assessment of members of the management body, and the suitability assessment of shareholders and members with qualifying holdings of issuers of ARTs, and of CASPs. |
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ESMA consults on Technical Standards under MiCA |
On 5 October 2023, ESMA launched its second consultation (here) on draft technical standards published under the MiCA Regulation. Stakeholders are invited to provide feedback in relation to draft technical standards on the following:
Comments can be made on ESMA’s proposed standards until 14 December 2023. ESMA will publish a final report on the basis of feedback received, and submit to the European Commission, by 30 June 2024, the final draft technical standards for review. |
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BCBS consults on Templates for Disclosure of Crypto-Asset Exposures |
On 17 October 2023, the BCBS launched a consultation (here) on disclosure templates that it has developed for banks in respect of disclosing exposures to crypto-assets. The consultation runs until 31 January 2024. Feedback can be submitted by both market participants and by the general public. |
| Other | |
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Selected Consultations, Discussion Papers, Speeches and Reports Published |
CBI – Bank Lending Survey Results: October 2023 (here) CPMI – Report on Considerations for the Use of Stablecoin Arrangements in Cross-Border Payments (here) Council of the EU – Council Conclusions on Digital Empowerment to Protect and Enforce Fundamental Rights in the Digital Age (here) ECB – Euro Area Bank Lending Survey: October 2023 (here) ECB – Monetary Policy Statement: October 2023 (here) ECB – Supervisory Banking Statistics on Significant Institutions: Q2 2023 (here) EIOPA – European Insurance Overview 2023 (here) EIOPA – Impact of Inflation on the Insurance Sector (here) ESAs – Criteria on the Independence of Supervisory Authorities (here) ESMA – “Be Ready for the Digital Age” (remarks by Verena Ross, ESMA Chair) (here) ESMA – “ESG Names and Claims in the EU Fund Industry” (report) (here) ESMA – Q&As on MiFID II and MiFIR Market Structure Topics (updated 13 October 2023) (here) ESMA – Q&As on MiFID II and MiFIR Transparency Topics (updated 27 October 2023) (here) ESMA – Results of the Fact-Finding Exercise on Corporate Reporting Practices under the EU Taxonomy Regulation (here) ESMA – “The Heat is On: Disclosures of Climate-related Matters in Financial Statements” (report) (here) European Commission – Call for Evidence: Administrative Burden – Rationalisation of Reporting Requirements (here) (call for evidence runs until 28 November 2023) European Commission – Commission Work Programme 2024 (here) European Commission – “The Sustainable Finance Disclosure Regulation – what next?” (remarks by Mairead McGuinness, European Commissioner for Financial Stability, Financial Services and the Capital Markets Union) (here) European Commission – Third Annual Report on the Screening of Foreign Direct Investment into the EU (here) European Money Markets Institute (“EMMI”) – Consultation Paper on Enhancements to EURIBOR’s Hybrid Methodology (here) (consultation runs until 11 December 2023) Insurance Ireland – Protecting Tomorrow: the Future of the Irish Insurance Industry (here) International Capital Markets Association (“ICMA”) – ICMA Quarterly Report: Q4 2023 (here) ICMA – Market Integrity and Greenwashing Risks in Sustainable Finance (here) International Swaps and Derivatives Association (“ISDA”) – ISDA in Review: October 2023 (here) |
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This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.
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