Independent Investment Management Initiative – Response to FCA Consultation Paper CP 24/2 – ‘Our Enforcement Guide and publicising enforcement investigations–a new approach’
IIMI welcomes the opportunity to respond to the FCA’s Consultation Paper CP 24/2, Part 2. However, we do not believe that the FCA has demonstrated a sufficient need to introduce these proposals. The case for change has not been sufficiently made. Alternative approaches, which would be less harmful to smaller businesses and better align with the FCA’s competition objectives, have not been sufficiently explored before advancing these proposals.
As a representative body for small boutique investment managers, we recognise the importance of maintaining market integrity and ensuring investor protection. However, we have significant concerns about the proportionality of the proposed measures, particularly regarding the principle of “innocent until proven guilty” and the cost implications for smaller firms.
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