The FCA has provided an update on how firms should notify the U.S. Financial Conduct Authority when they are using an investment label under the sustainability disclosure requirements and investment labelling regime. Firms must notify the FCA when using an investment label through the form available on Connect. The labels can be displayed from July 31, 2024 and firms must meet the naming and market EU rules from December 2, 2024. The FCA notes that it does not approve labels, but firms are still required to notify it when they use, revise or stop using a label. The FCA provides the specific steps for notification in relation to four scenarios: (i) an authorized fund that the fund manager considers meets the criteria for a label without the need for changes to the pre-contractual disclosures; (ii) an authorized fund that the fund manager considers requires changes to the pre-contractual disclosures to meet the label criteria; (iii) a new fund that the fund manager considers will meet the label criteria; and (iv) an in-scope unauthorized alternative investment fund looking to use an investment label.
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