A significant change to the U.K. prudential framework for investment management firms will soon take effect as a result of the new U.K. Investment Firms Prudential Regime (IFPR). Although a purely U.S.‑based manager will not be affected by the IFPR, a U.S. manager’s U.K. sub‑advisory affiliate would likely be in scope. In a guest article, Leonard Ng and Qalid Mohamed, partner and associate, respectively, at Sidley Austin, enumerate ten key issues that U.K. investment managers should consider and address as they implement the new rules. Given that investment managers have varied business models, it will be important for each manager to take advice that is specific to its business model; however, the observations in this article provide fund managers with a good starting point. For additional commentary from Ng, see “FCA Details Shortcomings of ‘Host’ Authorized Fund Managers
” (Aug. 26, 2021).