Following the City of London Law Society (CLLS)’s response to HM Treasury's September consultation on amending the definition of financial advice in article 53 RAO last week, the Law Society has now published its response. In its response, as well as commenting on the specific questions raised in the consultation, the Law Society calls for reconsideration of the regulatory perimeter under FSMA in the light of the legislative changes needed to implement Brexit. The Law Society also argues that there may be scope for reconsidering and simplifying certain areas of the current regulatory perimeter, such as: (i) the "by way of business" test; (ii) the regulated activities of dealing as principal, dealing as agent and arranging deals in investments, as specified in the RAO, and the extent to which they provide meaningful additional investor protection; (iii) the definition of a CIS and whether this definition, and the restriction on promoting CISs in section 238 of FSMA, is necessary given the EU concepts of UCITS and AIFs; and (iv) the financial promotion regime. The Law Society comments that there is no clear exemption for reverse solicitation or to allow the solicitation of expatriates by regulated businesses from their home jurisdictions.