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Thinking - Blog

Government consults on regulation of Buy-Now Pay-Later products

Published on 25 Oct 2024. By Whitney Simpson, Of Counsel and Lucy Hadrill, Associate

In 2021, HM Treasury announced its intention to regulate certain unregulated buy-now pay-later (BNPL) products in the UK. This followed recommendations made in the Woolard Review which raised concerns about the increased use of BNPL products during the pandemic and the significant risk that these unregulated credit products could cause consumer harm.

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Thinking - Blog

FCA consults on changes to the payments safeguarding regime

Published on 24 Oct 2024. By Whitney Simpson, Of Counsel and Lucy Hadrill, Associate

Under the Payment Services Regulations 2017 (PSRs) and the E-Money Regulations 2011 (EMRs) payment institutions (PIs), electronic money institutions (EMIs), small EMIs and credit unions are required to protect "relevant funds" which they receive when making a payment or in exchange for e-money that has been issued. Current safeguarding requirements are set out in the PSRs and EMRs, with guidance contained in the Financial Conduct Authority's (FCA) Approach Document.

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Thinking - Blog

How should Financial Institutions manage the rise of non-financial misconduct?

Published on 19 Feb 2024. By James Wickes, Partner and Amber Slumbers, Associate

Over the last few months, Parliament's Treasury Committee has sought to examine the many barriers faced by women in financial services through the aptly named "Sexism in the City" inquiry.

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Thinking - Blog

Quid game – fixed costs; pick your battles

Published on 30 Jan 2024. By Thom Lumley, Partner and Chris Gower, Senior Associate and Sally Lord, Knowledge Lawyer Manager

Ordinarily, the claims that make the headlines are those that have the highest value or the most significant impact on the public. With the costs landscape ever-changing in civil claims, without careful planning and strategy, even modest claims can end up biting defendants in the longer-term.

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Thinking - Blog

Castle caper condoned? Court of Appeal rules on dishonest condonation and aggregation under solicitors policy in Discovery Land v AXIS

Published on 17 Jan 2024. By Graham Reid, Partner and Will Sefton, Partner and Head of the Lawyers Liability and Regulatory Group and Aimee Talbot, Knowledge Lawyer

On 15 January 2024 the Court of Appeal handed down judgment in Discovery Land Company LLC and others v Axis Specialty Europe SE [2024] EWCA Civ 7. The case concerns the ability of a solicitors’ insurer to decline cover for a claim on grounds of dishonesty and, in particular, the meaning of “condonation” of dishonesty. It also concerns how the aggregation clause operates in a solicitors’ professional indemnity insurance policy.

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Thinking - Publication

Law passed to regulate Significant Investments in Singapore Entities

Published on 12 Jan 2024. By Kenneth Leong, Partner and Jemima Holly Ang, Associate

The Significant Investments Review Bill (the "Bill") was recently passed by Parliament on 9 January 2024, and is expected to take effect in the first half of the year.

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Thinking - Blog

The Terminator: A Tale of Two Insurance Claims

Published on 19 Dec 2023. By Peter Mansfield, Partner

It is 2029, and the Machines are losing their war with Humanity. What to do?

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Thinking - Blog

Project Angel Bidco v AXIS - what are the key takeaways for warranty and indemnity insurers?

Published on 30 Nov 2023. By James Wickes, Partner and Matthew Wood, Senior Associate and Matt Ward, Associate

On 31 October 2023, the London Circuit Commercial Court gave judgment in Project Angel Bidco Limited (in administration) v Axis Managing Agency Limited & Ors (2023) EWHC 2649.

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Thinking - Blog

Wordings do matter

Published on 06 Nov 2023.

Contract drafting has been brass tacks for lawyers since the dawn of time. In its broadest terms, it involves putting the scope of a bargain reached between parties into clear and effective language.

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Thinking - Blog

Storm Babet, flooding and the insurance implications

Published on 24 Oct 2023. By Victoria Sherratt, Partner and Andrew Roper, Partner and Aimee Talbot, Knowledge Lawyer

Subtropical cyclone Storm Babet is currently responsible for over 350 flood warnings in the UK, with more flood warnings expected later this week.

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Thinking - Blog

Getting to know Global Access Lawyers

Published on 09 Oct 2023. By Carmel Green, Partner and Simon Laird, Global Head of Insurance

Global Access Lawyers brings together some of the worlds leading insurance law practices. In the following pages get to know the different law firms that make up Global Access, who we are, where we operate and the kind of work we do. We hope you find this useful to understand the international reach of Global Access.

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Thinking - Blog

Court of Appeal finds in favour of FSCS on scope of the Policyholder Protection Rules (PRR)

Published on 14 Sep 2023.

The Court of Appeal has upheld an appeal by the FSCS from a High Court decision to grant an application for JR against FSCS following FSCS's refusal to compensate a policyholder for an insolvent insurer's failure to meet its liabilities.

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Thinking - Blog

What does the FRC's proposed corporate governance overhaul mean for D&O exposures?

Published on 04 Jul 2023. By James Wickes, Partner and Aimee Talbot, Knowledge Lawyer

The Financial Reporting Council (FRC) has now published the draft new UK Corporate Governance Code following the Government's requirements that it incorporate more robust internal control and prudent and effective risk management requirements. The deadline for responses to the FRC's consultation is 13 September 2023.

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Thinking - Blog

Consumer duty and claims handling – beware of sludge practices

Published on 10 May 2023. By Jonathan Charwat, Partner

The Consumer Duty is a new regulatory framework developed by the Financial Conduct Authority (FCA) aimed at creating a higher standard of consumer protection in the retail markets. The FCA expects the Consumer Duty to be a significant shift for the market in terms of its expectations on firms and in this blog we consider this shift in the context of insurance claims handling.

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Thinking - Blog

FOS complaints and hindsight – categorical statement from the Chief Ombudsman

Published on 11 May 2020. By Rachael Healey, Partner

The FCA has been producing a range of temporary measures with the aim of ensuring that firms can work at pace during the pandemic for the benefit of customers. However, where procedures are bypassed or corners cut what will FOS do in response? The response from FOS to that questions raises another – the use of hindsight when coming to its decisions.

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Thinking - Blog

Bossing the rules

Published on 03 Dec 2019. By Aimee Talbot, Knowledge Lawyer

Watch out for RPC's new blog mini-series on the SRA Standards and Regulations 2019.

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Thinking - Blog

FCA issues Final Report in the Wholesale Insurance Broker Market Study

Published on 20 Feb 2019. By Matthew Griffith, Partner and Jonathan Charwat, Partner

Today, the FCA released its Final Report in its Wholesale Insurance Broker Market Study. The study, which was launched in 2017, considered competition, transparency and conflicts concerns arising from changes in the market, including an increased use of broker facilities.

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Thinking - Blog

Accountants, auditors and actuaries beware: the FRC continues to show its teeth, as its future stands in the balance

Published on 18 Jul 2018. By Rachel Ford, Partner

In widely publicised news, the Financial Reporting Council (FRC) continues to levy record high fines and has cast criticism on a number of firms. What appears to be an unforgiving stance taken by the regulator seems to come in the wake of the review into whether or not it should be disbanded, or folded into another regulatory organisation.

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Thinking - Blog

The future of SIPPs – FCA responds to the Work and Pensions Committee

Published on 05 Jul 2018. By Rachael Healey, Partner

A couple of weeks ago we reported on 5 pointed questions raised by the Work and Pensions Committee of the FCA in relation to the SIPP market. Those questions included whether or not the FCA was considering banning non-standard investments in SIPPs. The FCA has now responded. The response includes the FCA's views on the due diligence it expects of SIPP providers when it comes to non-standard investments.

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Thinking - Blog

PRA consultation to promote diversity on boards of large insurers

Published on 06 Jul 2017.

The PRA consults on further amendments to the Senior Insurance Managers Regime (SIMR) including promoting diversity on boards.

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Thinking - Snapshot

CMA investigates Ticketmaster for dynamic pricing of Oasis tickets

Published on 10 Dec 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

Can dynamic pricing breach consumer protection rules?

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Thinking - Snapshot

CMA publishes guidance for fashion retailers on environmental claims

Published on 10 Dec 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

How best can fashion retailers protect themselves from regulatory action when making green claims?

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Thinking - Snapshot

CJEU rules on pricing display strategies of Aldi Süd

Published on 10 Dec 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

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Thinking - Snapshot

European consumer body challenges in-game premium currencies

Published on 10 Dec 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

When does the use of in-app and in-game premium currencies pose consumer regulatory issues? Does this consumer complaint herald a tightening by the EU on revenue streams for game and app developers and platforms?

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Thinking - Snapshot

UK pricing practices in the spotlight

Published on 10 Dec 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What should businesses take note of recent amendments to the UK’s Price Marking Order and the CMA’s newly published report on loyalty pricing?

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Thinking - Snapshot

News Flash: Timeline for the Digital Markets, Competition and Consumers Act

Published on 10 Dec 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

On 24 May 2024, the UK’s Digital Markets, Competition and Consumers Act (DMCCA) received Royal Assent.

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Thinking - Publication

A new era for sustainability consumer products: the EU’s new Ecodesign for Sustainable Products Regulation (ESPR)

Published on 20 Nov 2024. By Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead and Sophie Parkinson, Associate

On 18 July 2024 the ESPR entered into force setting a framework for new ecodesign rules in the EU. It will have significant impacts for retailers and consumer brands selling products in the EU. It will introduce new minimum ecodesign requirements for specific product categories (with an initial focus on textiles), make digital product passports mandatory and set rules on the destruction of unsold products. Companies face the risk of fines, consumer claims and reputational damage for non-compliance.

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Thinking - Publication

Product liability and safety legislative refurb

Published on 05 Nov 2024. By Gavin Reese, Partner, Head of Regulatory and Sally Lord, Knowledge Lawyer Manager

The current legislation governing product safety is the General Product Safety Directive (GPSD), but its shortcomings, especially on tech, are evident.On 13 December 2024 the EU will be replacing the GPSD with the General Product Safety Regulation (GPSR), and the latest King’s Speech indicated it will be replaced in the UK by a Product Safety and Metrology Bill.Separately, EU Member States are rolling out a revised Product Liability Directive (PLD) which captures the provision of software, digital services and online marketplaces.

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Thinking - Publication

The EU Compliance headache you don't know you have? A priority primer on the European Accessibility Act

Published on 31 Oct 2024. By Oliver Bray, Senior Partner and Hettie Homewood , Senior Associate

It is now less than a year until the EU Accessibility Act (EAA) comes into force, which will require businesses to ensure a range of products (eg smartphones and computers) and services (eg e-commerce services, consumer banking services, and ebooks) are accessible for persons with disabilities.

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Thinking - Publication

Seeing the wood for the trees: preparing for new deforestation due diligence rules in the UK and EU

Published on 24 Oct 2024. By Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead

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Thinking - Snapshot

Urgently Misleading: the CMA secures undertakings from Wowcher and £4 million of customer refunds

Published on 17 Oct 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

When does a selling practice create a false sense of urgency that is considered misleading by the Competition and Markets Authority (CMA)?

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Thinking - Snapshot

Exemption from HFSS product restrictions for Ofcom-regulated internet protocol television (IPTV) services

Published on 17 Oct 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What is the UK Government's proposal for the incoming HFSS restrictions in relation to IPTV advertising?

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Thinking - Snapshot

CMA targets Simba for misleading online choice architecture

Published on 17 Oct 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What types of promotional tactics are in the Competition and Markets Authority's (CMA) line of sight when it comes to misleading online choice architecture?

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Thinking - Snapshot

CMA publishes draft guidance on enforcement of DMCCA consumer law

Published on 17 Oct 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

How will the CMA look to enforce the consumer protection law sections of the recently enacted Digital Markets, Competition and Consumers Act 2024 (DMCCA)?

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Press and Media

Navigating retail's sustainable revolution as ESG shapes the industry's future

Published on 02 Oct 2024. By Kimberley Nanson, Senior Communications Manager and Caroline Copland, Head of Marketing Communications

As the retail regulatory landscape continues to develop at pace and affordability and sustainability remain important for consumers, ESG poses a variety of opportunities and challenges for those in the retail and consumer market.

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Thinking - Publication

Retail Compass Autumn 2024

Published on 02 Oct 2024. By Jeremy Drew, Partner and Karen Hendy, Partner and Ciara Cullen, Partner

Welcome to the autumn edition of Retail Compass. This edition sees a surge of ESG-related legislative and regulatory updates. We hope to guide you through the most pressing, as well as the wider upcoming legal and policy changes affecting retail and consumer brands.

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Thinking - Blog

Top tips for Influencing Senior Stakeholders on Environmental Programmes: Insights from a Responsible Business Professional

Published on 25 Sep 2024. By Katie Horn, DEIB and Responsible Business Manager (Market Facing)

Effectively influencing senior stakeholders is essential for the success of Environmental, Social, and Governance (ESG) programmes.

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Thinking - Snapshot

The EU’s Product Liability Directive expands to cover digital technology

Published on 01 Aug 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What changes to civil product liability have been implemented by the European Commission for defective digital products and software?

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Thinking - Snapshot

Product Security and Telecommunications Infrastructure Regulations: a new security regime for smart devices

Published on 01 Aug 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What does the new cyber security regime mean for “smart” devices in the UK?

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Thinking - Snapshot

Empowering consumers through the EU’s Green Transition Directive

Published on 01 Aug 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What are the enhanced consumers rights arising from the EU’s Directive on Empowering Consumers for the Green Transition (the Empowering Consumers Directive)?

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Thinking - Snapshot

The EU’s new General Product Safety Regulation is set to land in December 2024

Published on 01 Aug 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What do manufacturers and online marketplaces need to think about as the EU General Product Safety Regulation (GPSR) comes into force in December 2024?

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Thinking - Snapshot

The Digital Markets, Competition and Consumers Act becomes law

Published on 01 Aug 2024. By Oliver Bray, Senior Partner and David Cran, Partner, Head of IP & Tech

What changes will the new Digital Markets, Competition and Consumers Act bring to the consumer protection and competition regulation landscape?

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Thinking - Blog

The EU's Green Claims Directive

Published on 24 Jul 2024. By Oliver Bray, Senior Partner and Ciara Cullen, Partner and Hettie Homewood , Senior Associate and Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead

The EU's proposed Green Claims Directive (GCD) sets out expansive new rules for companies making green claims in the EU.

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Thinking - Blog

Parliamentary 'wash up' – which Bills made it through?

Published on 31 May 2024. By Paul Joukador, Partner and Praveeta Thayalan, Knowledge Lawyer and Shahil Goodka, Trainee Solicitor

On 22 May 2024, Prime Minister Rishi Sunak announced that a General Election will take place on 4 July 2024. Parliament was then prorogued on 24 May 2024 which allowed a mere 2 days for 'wash up' - the process by which outstanding bills may be rushed through the parliamentary process.

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Thinking - Blog

Consumer friendly compliance – guidance for retailers and consumer brands on the DMCC Bill

Published on 15 May 2024. By Eve Matthews, Associate

Following receipt of some 372 responses to the "Smarter Regulation: Improving consumer price transparency and product information for consumers" Consultation, the government has published its response in which it proposes significant amends to the Price Marking Order alongside new additions to the DMCC Bill.

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Thinking - Blog

Higher stakes cybercrime – prepare now

Published on 08 May 2024. By Elizabeth Zang, Associate and Richard Breavington, Partner

Cybercrime continues to increase and shows no signs of stopping.

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Thinking - Blog

Food and beverage 2050: The transition to net zero

Published on 02 May 2024. By Karen Hendy, Partner, Head of Corporate and Rosamund Akayan, Knowledge Lawyer

Following publication in October 2023 of its final Disclosure Framework for private sector entities to transition to a net zero economy, the TPT published draft Food & Beverage Sector Guidance in November 2023.

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Thinking - Blog

Virtual advertising: a glimpse into the future

Published on 30 Apr 2024. By Elizabeth Alibhai, Partner and Lola Withrington, Associate

Virtual advertising and experiences are transforming the way real world property can be used by turning it into a canvas for digital content.

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Thinking - Blog

The rise of recommerce

Published on 25 Apr 2024. By Ciara Cullen, Partner and Emma Dunnill, Senior Associate

Recommerce (which includes reselling, renting, refilling, repairing or reusing goods) is already an extremely valuable business model, estimated by Barclays to be worth almost £7bn in the UK alone and expected by Visa to increase to £82bn by 2030. This growth – particularly in respect of resale – is widely regarded as being driven by Gen Z consumers, over two thirds of whom now prefer to buy second-hand over new goods, in part, due to sustainability concerns.

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Thinking - Snapshot

Collective actions under consumer law: proposed amendments to the Digital Markets, Competition and Consumers Bill

Published on 17 Apr 2024. By Oliver Bray, Senior Partner

Are class actions under consumer protection law likely following the UK’s new DMCC Bill, and if so, what will the impact on businesses be?

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