Back-up service facilitation: readiness cannot be assumed
ArticleBack-up servicing has moved from a documentation formality to a live risk management issue.
This week, UK and EU regulators are tidying the detail while keeping a steady eye on outcomes for consumers and markets.
We lead with the Financial Conduct Authority’s (FCA) decision to launch a review into Child Trust Funds, after HM Revenue and Customs (HMRC) figures showed hundreds of thousands of matured accounts sitting unclaimed, with some targeted by costly tracing services.
Next, the FCA turns to Handbook housekeeping, publishing its (53rd) quarterly consultation paper. The changes are minor individually, but span retail, wholesale and payments business, so most authorised firms will find something relevant.
Elsewhere, the Joint Money Laundering Steering Group (JMLSG) has finalised revisions to its anti-money laundering guidance, reflecting recent changes to the Money Laundering Regulations and this now awaits HM Treasury approval.
Finally this week, in Brussels, a new EU code of conduct for issuer-sponsored research has come into force under the Markets in Financial Instruments Directive II (MiFID II), widening access to good research whilst removing points of friction.
The FCA is launching a review into Child Trust Funds (CTFs), the savings accounts opened for children born between September 2002 and January 2011. HMRC figures show around 760,000 matured CTFs, worth an average of £2,000 each, remain unclaimed.
The review will examine why some young adults lose contact with providers once they turn 18, whether CTF holders receive fair value under the Consumer Duty, and whether vulnerable young adults face barriers to accessing their own money. It follows warnings that some firms charge as much as £400, or run ongoing subscriptions, to trace funds that HMRC’s own online tool finds for free. Tracing a CTF does not itself require FCA authorisation, so some providers fall outside the claims management fee cap and outside the jurisdiction of the FOS.
The FCA expects to report next year.
Read more on the FCA’s review of Child Trust Funds
The FCA has published its latest quarterly consultation paper, CP26/32, proposing various amendments to its Handbook. The proposals span retail, wholesale and payments rules, and comments are due by 12 October 2026.
Among the changes, the FCA proposes to:
Read more on CP26/32: Quarterly consultation paper No. 53
JMLSG has finalised revisions to Part I of its anti-money laundering and counter-terrorist financing guidance, covering customer due diligence, pooled client accounts and firms’ policies and controls. JMLSG consulted on the changes in June 2026, and the final text has now been submitted to HM Treasury for ministerial approval.
The revisions reflect amendments made to the Money Laundering Regulations 2017 by this year’s Money Laundering and Terrorist Financing (Amendment) Regulations 2026. Updates include a new exception from due diligence when opening an account for a customer of an insolvent UK bank, clearer guidance on verifying the identity of a person acting on behalf of a customer, and revised guidance on pooled client accounts. Courts and the FCA take account of JMLSG guidance when assessing whether a firm’s AML systems and controls are adequate.
Read more on the JMLSG’s revisions to Part I of its guidance
Commission Delegated Regulation (EU) 2026/1092, setting out an EU code of conduct for issuer-sponsored research, came into force on 7 September 2026, three days after publication in the Official Journal. It supplements Article 24(3c) of MiFID II, as amended by the Listing Act’s Listing Directive.
The code sets a single definition of issuer-sponsored research, applying only where the company under review has funded the work, wholly or in part, and where the research follows the code’s conduct standards. The European Commission’s aim is to widen reliance on high-quality issuer-sponsored research while removing obstacles for issuers seeking coverage. The regulation is based on draft technical standards the European Securities and Markets Authority (ESMA) submitted to the Commission in October 2025.
Issuers and research providers with EU operations should check existing research arrangements against the new code, since research falling short of its requirements can no longer carry the issuer-sponsored label.
Read more on the EU code of conduct for issuer-sponsored research
UK Regulatory Handbook 2026
An essential guide to the regulatory landscape for financial services
Back-up servicing has moved from a documentation formality to a live risk management issue.
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