The House of Commons meaningful vote on the draft Withdrawal Agreement

Jonathan Herbst

So, the Government didn't get the vote through tonight. The practical question is, what does that actually mean? Well, to put this in a bit of context, in simple terms, it shouldn't actually make any difference to people's Brexit planning. All of the plans that firms have been required to create have been on the assumption of no deal, and that has to be the current working assumption of what is going to happen. Now it may, of course, politically not be what ultimately happens, but in terms of commercial planning, that is a sensible approach. Our advice would be to carry on doing the work in a calm and sensible kind of way, and to keep a close eye on political developments. And just turning to those for a second, we don't know what's going to happen. Clearly, there are a spectrum of options here, right from a so-called hard Brexit, right over to a second referendum, or indeed no Brexit that could ultimately result from that. I think the simple point, if you're in front office, head of Compliance, or head of legal, or any other function, in a senior role, is just to carry on sending the message to the business, carry on with the planning in a sensible kind of way. So, other practical point to note is that it's important, if you're a European passporting firm, whether services or establishment, to get your notification in under the TPR [temporary permissions regime] by the end of 28 March 2019. As we know, those notification forms are there on the FCA website and the PRA website, and so just as important to take fully account of that. We've got all of the materials gathered on Regulation Tomorrow, which is our blog, and Brexit pathfinder within that.