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Letter - EIA to Jersey Finance re JFSC Increased Charges - 16 October 2023

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States Greffe

Joe Moynihan

Chief Executive Officer Jersey Finance

BY EMAIL

16th October 2023

Dear Mr Moynihan,

P.79/2023 Draft Financial Services (Disclosure and Provision of Information) (Amendment) (Jersey) Regulations 202-. and P.80/2023 Draft Limited Partnerships (Annual Addition Charge) (Amendment) (Jersey) Regulations 202-.

I am writing to you as Chair of the Economic and International Affairs Panel (the Panel) regarding two recently lodged propositions to the States Assembly as we would find further information useful in our work of scrutinising the proposed changes.

The Draft Financial Services (Disclosure and Provision of Information) (Amendment) (Jersey) Regulations 202-. (P.79/2023) and the Draft Limited Partnerships (Annual Addition Charge) (Amendment)  (Jersey)  Regulations  202-.  (P.80/2023)  (together,  the  Proposals)  propose  to increase the amount payable for the annual additional amount upon submission of an annual confirmation statement from £145 to £175.

The Proposals outline that the increase will not apply to local entities, but to those administered by a trust company business or fund services business as defined in the Financial Services (Jersey) Law 1998. The Proposals also indicate local entities provided with only Class O trust company  business  (formation  agent,  secretary,  registered  office,  nominee  shareholder  or unitholder) will not be subject to the increased fee.

The Panel understands that the Jersey Financial Services Commission will be carrying out a consultation on the Proposals, and note that Jersey Finance has previously aided in coordinating industry response to such consultations. As this consultation is running concurrently within the lodging period of the Proposals, the Panel would value the provision of any representation as to the industry’s views of:

Whether the increase in the amount payable is reasonable.

Whether the increase in the amount payable is well-timed.

Noting that the proposed Regulations will be debated shortly, we would be grateful if you could respond to this letter at your earliest convenience and would appreciate the provision of any comment on this matter.

If you have any questions regarding this or our work in general, please do not hesitate to contact me. Please note that, unless otherwise stated, all letters will be uploaded to the Scrutiny website as a matter of course.

Yours sincerely,

Deputy Moz Scott

Chair

Economic and International Affairs Scrutiny Panel