The UK FCA and PRA propose to implement the TPR if the UK leaves the European Union on 29 March 2019 without an implementation (or transitional) period, to ensure that EEA firms currently operating under an incoming passport (either from a UK branch or on a cross-border services basis into the UK) can continue to carry out regulated activities in the UK until they receive new direct authorisation by the UK regulators. An additional regime to address contractual continuity (the financial services contracts regime) is currently being consulted on by the FCA, and will be covered in a separate Herbert Smith Freehills briefing.
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