Reed Smith Client Alerts

COVID-19 will raise new challenges for regulated firms (Firms) and will stress test the adequacy of their business continuity plans (BCP) as well as their ability to comply with regulatory requirements and ensure continuity of service to customers.


Regulators are actively engaging with Firms in order to better understand the challenges that exist and ensure that customers are protected and markets continue to function well. Whilst Firms will understandably be focused on keeping their businesses on track, Regulators will expect Firms to take all reasonable steps to comply with their regulatory requirements.

Regulators have also made it clear that they expect Firms to consider the needs of customers when responding to the challenges posed by COVID-19 and are expecting Firms to go beyond usual ‘business practice’. In this regard, the Financial Conduct Authority (FCA) has made it clear that it does not expect Firms to exercise contractual rights based solely on legal technical grounds, rather that consideration should also be given to the impact this may have on customers. Regulators will expect Firms to communicate clearly and early with their customers to address any challenges and concerns.

Regulators acknowledge the challenges that COVID-19 poses and are updating their approach as the situation develops, so Firms should continue to monitor developments to ensure that they understand Regulators’ expectations.