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Responses and representations 2012


HMT consultation on implementing the Wheatley Review
IMA response (20 December)

FSB recommendations to strengthen the oversight of shadow banking
IMA response (20 December)

EC: Recovery and Resolution Frameworks for Non-Banks
IMA response (20 December)

FSA paper: Captial requirements for SIPP operators
IMA response (17 December)

FSA: Journey To The FCA – prudential requirements
IMA response (12 December)

HMT consultation on authority for tools to be used by the Financial Policy Committee
IMA response (12 December)

ESMA guidelines on remuneration policies and practices
IMA response (7 December)

FSB paper: Recovery and resolution planning
IMA response (4 December)

FSA CP12/22: Client assets regime
IMA response (4 December)

FSA CP12/27: Quarterly Consultation No 34 - Chapter 8 proposed COLL changes
IMA response (4 December)

EU Audit Proposals
IIC paper (3 December)


EC consultation on Regulation of indices
IMA response (29 November)

ONS paper on Retail Prices Index
IMA response (29 November)

FSA CP12/19: Restrictions on the retail distribution of UCIS
IMA response (16 November)

IASB post- implementation review - IFRS 8 Operating Segments
IMA response (16 November)

Implementing UK-US FATCA agreement
IMA response (16 November)

BIS The Future of Narrative Reporting
IMA response (14 November)


FSA CP12/16: FSA Funding Model Review
IMA response (24 October)
Hogan Lovells paper (22 October)

HMRC consultation on Anti-avoidance, attribution of gains, transfer of assets
IMA response (22 October)

EC consultation on UCITS investment strategies and other issues
IMA response (18 October)

FSA CP12/22 on Client assets regime
IMA response (16 October)

IAASB consultation on Improving the Auditor’s Report
IMA response (11 October)

FSA consultation on Client Assets firm classification
IMA response (1 October)


BIS Consultation Paper on Directors' Pay
IMA response (28 September)

FSA consultation on Payments to platform service providers
IMA response (27 September)

ESMA consultation on Remuneration under MiFID
IMA response (27 September)

ESMA consultation on repo and reverse repo arrangements
IMA response (25 September)

HMT Consultation on Financial sector resolution: broadening the regime
IMA response (24 September)

ECON consultation on Market manipulation: Lessons and reform post LIBOR/EURIBOR
IMA response (17 September)

Wheatley Review of LIBORIMA response (10 September)


DMO consultation on super-long and perpetual gilts
IMA response (21 August)

HMRC second consultation on the taxation of UUTs
IMA response (16 August)

HMT consultation on proposed changes to the Money Laundering Regulations 2007
IMA response (14 August)

ESMA consultation on OTC derivatives clearing
IMA response (3 August)

IOSCO consultation on CIS Liquidity Risk Management
IMA response (2 August)


FRC consultation on Revisions to the UK Stewardship Code
IMA Response (13 July)


IOSCO Principles for the Regulation of ETFs
IMA response (26 June)

FSA CP12/7: FSCS: changes to the Compensation sourcebook
IMA response (26 June)

ESMA DP: An Overview of the Proxy Advisory Industry, Considerations on Possible Policy Options
IMA response (25 June)

European Commission Green Paper on Shadow Banking

IMA response (15 June)

ESMA call for evidence on Transaction Reporting
IMA response (1 June)


IOSCO Consultation: Suitability Requirements with respect to the Distribution of Complex Financial Products
IMA response (18 May)

IOSCO consultation: Principles for the valuation of CIS
IMA response (18 May)

HMT paper on AIFMD
IMA response (8 May)

FSA consultation on tax-transparent funds
IMA response (4 May)

FSA guidance consultation on bribery and corruption controls
IMA response (4 May)

FSA CP12/2: Amendments to the Listing, Prospectus, Disclosure and Transparency RulesIMA response (3 May)


ASB consultation on the Future of UK GAAP and the SORP
IMA response (30 April)

The Kay Review – Interim report
IMA response (27 April)

BIS consultation on Executive pay
IMA response (27 April)

US Treasury and IRS: Proposed FATCA regulations
IMA response (27 April)

HMRC ISA Bulletin 42
IMA response (24 April)

ESMA discussion paper on OTC derivatives
IMA response (2 April)


ESMA guidelines on ETFs and other UCITS issues
IMA response (29 March)

Hearing of Legal Affairs Committee, European Parliament "Improving audit quality across the European Union",
IMA statement (March 2012)

FSA discussion paper 12/1: Implementation of the AIFMD
IMA response (23 March)

DWP consultation on improving transfers and dealing with small pension pots
IMA response (23 March)

ESMA discussion paper on on key concepts of AIFMD and types of AIFM
IMA response (23 March)

HMT consultation on tax-transparent funds
IMA response (19 March)

ESMA discussion paper on OTC Derivatives
IMA response (16 March)

IASB Exposure Draft on Revenue from contracts with customers
IMA response (13 March)

ESMA consultation on Short Selling
IMA response (9 March)


ESMA Consultation on Suitability
IMA response (24 February)

ESMA Consultation on Compliance
IMA response (24 February)

FSA CP11/23: Permitted Links – Final Response to FSA consultation
IMA response (13 February)

Volcker Rule
IMA response (13 February)

OECD Model Tax Convention: Definition of "permanent establishment"
IMA response (6 February)

FSA CP11/21: Fees and levies (Question 2)
IMA response (3 February)


HMRC Review of Double Taxation Treaties
IMA response (31 January)

Ferber MiFID II Questionnaire
IMA response (16 January)

FSA Retail Distribution Review - Treatment of Legacy Assets
IMA response (16 January)

Proposals to reform the Financial Reporting Council
IMA response (9 January)

Final response to CP11/21: Fees and levies
IMA response (6 January)

EIOPA Consultation on IORP Review
IMA response (3 January)