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Portrait ofPaul Edmondson

Paul Edmondson

Partner

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London
EC4N 6AF
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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Education

  • MA Law, Trinity College, Cambridge
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08/01/2024
Switzerland and the UK sign agreement on mutual recognition in financial...
On 21 December 2023, the Swiss Federal Council and HM Treasury in the UK announced the signing of an agreement on mutual recognition in specific areas of financial services between Switzerland and the UK referred to as the Berne Financial Services Agreement (the Agreement). The conclusion of this ground-breaking Agreement is the culmination of more than two years of negotiations following the signing of a Joint Statement on 30 June 2020 aiming at enhancing cooperation in financial services between Switzerland and the UK. 
07/02/2023
Insurer Resolution Regime will be time- and re­source-in­tens­ive for firms...
HM Treasury is proposing to introduce an Insurer Resolution Regime (IRR). The regime will provide the Bank of England (BoE) with tools to manage the failure of insurance companies. The aim of the proposed...
03/08/2022
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.
03/08/2022
FCA Consumer Duty - Implementation Toolkit
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...
03/08/2022
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’...
21/06/2022
Financial Services Future Regulatory Framework: A bonfire of investor protection?
What are the 3 main points made in the report? First, not to change too much. While UK regulation can be tailored or simplified, the TSC doesn’t want to see too much change, or for it to happen too...
21/06/2022
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...
09/06/2022
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...
25/01/2022
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...
25/01/2022
The Temporary Transitional Power (TTP) ends on 31 March: What Next?
What is the TTP? Since the transition period following the UK’s exit from the European Union ended at 11pm on 31 December 2020, “onshored” EU legislation has formed part of UK law. “On­shor­ing”...
09/12/2021
Reforming the Appointed Representative regime
HMT’s call for evidence HMT has overall responsibility for the legislative framework for the regulation of ARs. The FCA is responsible for the regulation and supervision of principal firms. HMT has...
09/12/2021
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...