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Portrait of Paul Edmondson

Paul Edmondson


CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English

Paul Edmondson is a partner in our Financial Services & Products team. He has over 20 years’ experience advising financial institutions on a range of regulatory and commercial issues.

Clients include banks, insurance companies (life and non-life), investment managers, insurance intermediaries, managing agents, broker-dealers and platforms, as well as the large corporate/pension fund clients of these institutions.

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“A strong technician”, Paul is recognised as a “Leading Individual” for both financial services and insurance regulation

Legal 500, 2015

Relevant experience

  • Regulatory change projects –insurers on Solvency II, fund managers on AIFMD and investment firms on MiFID II.
  • Governance –banks and insurers on the implementation of the senior managers regime
  • New products and services - advising a multi-national consultancy and investment manager on the development and launch of a range of pension products and a strategic tie-up with a platform and administration provider.
  • New distribution –a high street bank on multi-channel, multi-country distribution agreements with insurers.
  • Reorganisation –an international insurance group on a pan-European reorganisation in 18 countries through Part VII transfers and cross-border mergers and helping a high street bank to restructure its wealth management and advice offering.
  • Preparing for regulator visits –an insurance company for an FCA visit under the firm systematic framework and advising on the firm’s response.
  • Compliance with PRA and FCA rules and EU regulation – a wide range of prudential, governance and conduct issues.
  • Section 166 (skilled person appointments) – a global broker on how to handle and respond to a section 166 investigation.
  • Getting authorised – obtaining PRA/FCA/FSA authorisation for numerous insurers, investment managers, mortgage lenders, brokers and intermediaries.
  • Commercial contracts – drafting and negotiating a wide range of commercial contracts including investment management, custody, platform, distribution and outsourcing agreements.
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  • MA Law, Trinity College, Cambridge
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FCA Con­sumer Duty – Im­ple­ment­a­tion Toolkit
FCA has pub­lished its fi­nal rules and guid­ance for a new Con­sumer Duty that will set high­er and clear­er stand­ards of con­sumer pro­tec­tion across fin­an­cial ser­vices and re­quire firms to put their cus­tom­ers’ needs first.Act­ing to de­liv­er good out­comes should be at the centre of firms’ strategies and busi­ness ob­ject­ives.FCA wants to see in­creased con­fid­ence from con­sumers, en­sur­ing they are equipped with the right in­form­a­tion and the right sup­port to make ef­fect­ive, timely and prop­erly in­formed de­cisions.  The Duty in­cludes re­quire­ments for firms to: give fair value;en­sure cus­tom­ers don’t face un­reas­on­able bar­ri­ers when they want to switch or can­cel products or com­plain;provide help­ful and ac­cess­ible cus­tom­er sup­port;take ap­pro­pri­ate ac­tion to mit­ig­ate the risk of ac­tu­al or fore­see­able harm;provide timely and clear in­form­a­tion about products and ser­vices that cus­tom­ers can un­der­stand so they can make good fin­an­cial de­cisions;provide products and ser­vices that are right for their cus­tom­ers; and­fo­cus on the real and di­verse needs of their cus­tom­ers, in­clud­ing those in vul­ner­able cir­cum­stances, at every stage and in each in­ter­ac­tion.Throughout, the FCA ref­er­ences a re­newed fo­cus on the need for firms to un­der­stand how their cus­tom­ers be­have in prac­tice and how they make de­cisions. Firms will need to be able to demon­strate that they have con­sidered con­sumer be­ha­vi­our­al bi­ases at all stages of the product li­fe­cycle.The rules re­quire firms to mon­it­or and reg­u­larly re­view the out­comes their cus­tom­ers are ex­per­i­en­cing to en­sure that their products and ser­vices de­liv­er good out­comes and to take ac­tion where this is not the case. The con­sumer duty is also re­flec­ted in the SM&CR, with re­spons­ib­il­it­ies on seni­or man­agers and all con­duct rules staff to act to de­liv­er good cus­tom­er out­comes. The FCA is giv­ing firms 12 months to im­ple­ment the new rules for all new and ex­ist­ing products and ser­vices. The rules will be ex­ten­ded to closed book products 12 months later, to give firms more time to re­view what may be a large num­ber of closed products. Firms are ex­pec­ted to make full use of the im­ple­ment­a­tion peri­ods – FCA has set down a timetable of key mile­stones, the first of which is the end of Oc­to­ber 2022 when boards (or equi­val­ent bod­ies) are ex­pec­ted to have scru­tin­ised and agreed their firms’ im­ple­ment­a­tion plans.How the duty ap­plies and what it means in prac­tice will vary by sec­tor and by firm. Some firms will already be meet­ing parts of the new stand­ards through their com­pli­ance with ex­ist­ing hand­book pro­vi­sions, and the Duty will ap­ply pro­por­tion­ately de­pend­ing on the nature of firms’ of­fer­ings and their cus­tom­er base. But all firms will need to map their busi­ness to the new Duty and be able to evid­ence how they are mon­it­or­ing and act­ing to de­liv­er good out­comes.  The im­ple­ment­a­tion timetable is likely to prove chal­len­ging and firms will need to be­gin as­sess­ing their busi­ness and what the Duty means for them without delay. To help you nav­ig­ate this pro­cess, we have cre­ated our Con­sumer Duty Toolkit set­ting out the steps for firms to con­sider and how we can sup­port you through your im­ple­ment­a­tion pro­grammes.
Fin­an­cial Ser­vices Fu­ture Reg­u­lat­ory Frame­work: A bon­fire of in­vestor pro­tec­tion?
The House of Com­mons Treas­ury Com­mit­tee (TSC) has pub­lished its second re­port on the fu­ture of fin­an­cial ser­vices reg­u­la­tion, con­sid­er­ing the pri­or­it­ies for reg­u­lat­ory change. Its find­ings strike an...
Crit­ic­al Third Parties to the fin­an­cial ser­vices sec­tor: the dawn of a...
Back­ground HMT has con­firmed that it will le­gis­late to per­mit UK fin­an­cial reg­u­lat­ors to dir­ectly over­see and su­per­vise (pre­vi­ously un­reg­u­lated) “crit­ic­al” third parties (“CT­Ps”) that provide...
The Tem­por­ary Trans­ition­al Power (TTP) ends on 31 March: What Next?
The ap­plic­a­tion of the FCA’s and PRA’s Tem­por­ary Trans­ition­al Power (TTP) will end on 31 March 2022. FCA and PRA au­thor­ised firms must en­sure that they com­ply with all “on­shored” EU le­gis­la­tion...
Re­form­ing the Ap­poin­ted Rep­res­ent­at­ive re­gime
On 3 Decem­ber, HMT pub­lished a call for evid­ence and the FCA pub­lished a con­sulta­tion pa­per on changes to the Ap­poin­ted Rep­res­ent­at­ive (AR) re­gime.  While HMT and the FCA both ac­know­ledge that the AR...
Re­mu­ner­a­tion: New MI­FID­PRU Re­mu­ner­a­tion Code
The FCA has now pub­lished its near fi­nal rules for the single re­mu­ner­a­tion code for MI­FID in­vest­ment firms. The new code will re­place the ex­ist­ing BI­PRU and IF­PRU Re­mu­ner­a­tion Codes and will be known...
5 things to take away from the FCA’s Busi­ness Plan
On 15 Ju­ly, the FCA pub­lished its Busi­ness Plan and set out its key pri­or­it­ies for the year ahead. There is much talk about the FCA’s own in­tern­al trans­form­a­tion pro­gramme and how the or­gan­isa­tion in­tends...
Brexit we­bin­ar on UK au­thor­isa­tion for EU fin­an­cial in­sti­tu­tions
The UK reg­u­lat­or has been writ­ing to EU fin­an­cial in­sti­tu­tions who (pre-Brexit) ex­er­cised pass­port rights in­to the UK to no­ti­fy them of the timetable and pro­cess for ap­ply­ing for full UK au­thor­isa­tion...
ESMA ob­serves ques­tion­able re­verse so­li­cit­a­tion prac­tices after Brexit
The EU-UK Trade and Co­oper­a­tion Agree­ment and the end of the Brexit trans­ition­al peri­od on 31 Decem­ber 2020 has res­ul­ted in sig­ni­fic­ant changes to EU-UK trade in fin­an­cial ser­vices. In par­tic­u­lar, UK...
What does the  EU-UK Trade and Co­oper­a­tion Agree­ment mean for fin­an­cial...
Fol­low­ing the end of the Brexit Trans­ition Peri­od, we as­sess the im­pact of the EU-UK Trade and Co­oper­a­tion Agree­ment on the UK fin­an­cial ser­vices sec­tor and set out our ana­lys­is of the key points be­low...
Ex­ec­ut­ive Re­mu­ner­a­tion
Re­mu­ner­a­tion is fun­da­ment­al to the suc­cess and strategy of any busi­ness. At­tract­ive and sus­tain­able com­pens­a­tion struc­tures can in­crease pro­ductiv­ity and prof­it­ab­il­ity, whilst also help­ing to at­tract...
We­bin­ar: Fo­cus­ing on fair­ness - Cul­ture and gov­ernance to de­liv­er fair...
The FCA wants firms to foster healthy cul­tures where con­duct and fair out­comes are at the fore­front of their busi­nesses.  In this we­bin­ar we will look how cul­ture and gov­ernance can sup­port pos­it­ive...