On 27 June, our cross border team held a dynamic discussion on CRD 6: Third Country Branches covering an overview of the key changes introduced by the directive.
We discussed the impact of the new authorisation requirements on both existing third country bank branches and third country banks that carry out core banking services on a cross border basis. Some of the current national exemptions will fall away and new exemptions will apply under CRD6 including for reverse solicitation and certain existing contracts. The directive provides for a risk based categorisation of third country branches and introduces a raft of new reporting requirements.
The upshot of all of this is that many firms will need to restructure or obtain authorisation as a branch in order to continue business and supervisors across the EU will be taking a more intensive approach to supervision, particularly if they consider that a branch or group of third country branches poses systemic risk.
The timeline for obtaining authorisation is relatively tight so firms need to start planning now to assess the extent to which they are caught by the new rules and whether they can benefit from exemptions.
Click here for a copy of the presentation slides.
Authored by Dominic Hill and Sinead Meany.
Hogan Lovells (Luxembourg) LLP is registered with the Luxembourg bar
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