Letter: Financial Services (Implementation of Legislation) Bill

The Financial Services (Implementation of Legislation) Bill provides the power to HM Treasury, in the event no deal is agreed between the U.K. and the E.U., to implement and make changes to a category of legislation which the Bill describes as “in-flight”. These are pieces of E.U. financial services legislation that: (1) have been adopted by the E.U., but do not yet apply so cannot be captured by the Withdrawal Act; or (2) are currently in negotiation and may be adopted within two years after exit day.

The FMLC has written a letter to HM Treasury raising two issues of uncertainty arising from this proposal.