On March 24, 2016, the Financial Conduct Authority published its Policy Statement and near-final rules requiring information to be provided to customers by a non-ring-fenced body. The rules will require a NRFB to provide information about its investment and commodities trading activities to individuals with financial assets of at least £250,000 who are account holders or who have applied to open an account. The information is intended to inform customers of the implication of banking with a NRFB entity in a group which includes a ring-fenced bank. The ringfencing regime is set to apply from January 1, 2019. The FCA intends to finalize the rules later in 2016. Publishing the near-final rules now is intended to give banks time to assess the implications before they implement their Ring Fencing Transfer Schemes. A bank will need to comply with the disclosure rules in the period immediately before its structural separation, although the disclosure would not have to be sent until a bank expects to receive a declaration of eligibility from a customer (i.e., a declaration that the customer has held assets of not less than £250,000 over a certain period).

The Policy Statement and Near-Final Rules are available at: http://www.fca.org.uk/static/documents/ps16-9.pdf