There are a number of significant legal and regulatory developments which are likely to have an impact on private equity managers in 2016 and the following sets out anticipated key dates for June and July 2016 which may be of interest, as follows:

  1. 6 to 9 June 2016: European Parliament to consider legislative proposals to delay MiFID II in its plenary session.
  2. 21 June 2016: First clearing obligations for interest rate derivatives under EMIR apply.
  3. June 2016: HM Treasury expected to lay before Parliament the Financial Services and Markets Act 2000 (Market Abuse) Regulations 2016. The Regulations will make the necessary amendments to primary and secondary legislation to implement the Market Abuse Regulation (MAR) in the UK.
  4. June 2016: European Commission expected to adopt delegated acts under the MLD4 identifying third countries with strategic money laundering or terrorist financing deficiencies (known as the blacklist).
  5. June 2016: European Commission likely to: (i) consult on elements of a European framework on loan origination; and (ii) publish white paper on funding and governance of European Supervisory Authorities (ESAs).
  6. By end of June 2016 at the latest: European Commission expected to publish a legislative proposal to amend MLD4 as part of its terrorist financing action plan.
  7. 3 July 2016. The majority of the provisions of MAR will apply (and the Market Abuse Directive (MAD) and its implementing legislation will be repealed).
  8. 3 July 2016. Member states (other than the UK and Denmark, having opted out) must transpose the provisions of the Directive on Criminal Sanctions for Market Abuse (CSMAD) into national law.
  9. 12 July 2016: Date from which all new funds are required to provide appropriate disclosures in their offering documentation relating to the SFT Regulation.
  10. July 2016: European Parliament expected to formally adopt the proposed Directive concerning measures to ensure a high common level of network and information security across the EU (known as the Cyber-security Directive, the Network and Information Security Directive or the NIS Directive).