ESMA and the FCA each yesterday issued updated documents relating to a potential “hard Brexit” on the 31st October:

ESMA issued:

• A public statement summarising the situation (here).
• A document on the use of UK data in different regulatory calculations which includes the use of UK data in the Ancillary Activity test (here).
• An operational data readiness plan (here).
• A document on “other issues”, which includes an updated statement on the application of the “REMIT carve out”, a statement on the application of position limits of contracts on UK venues and also the MiFID post trade transparency requirements of OTC transactions entered into between EU Investment Firms and UK firms (here).

The FCA published Market Watch 61, which reviews arrangements for reporting during the possible cut over as well as the local transparency regime (here).