Information on CP25/18 - October 2025

Annex A

1.     Copies of the non-confidential responses to CP25/18.

All non-confidential responses received will be released to you outside of FOIA as routine correspondence.  These responses will be sent to you under a separate cover by the relevant business area.

2.     A list of all the organisations/individuals who responded.

The following entities responded to the consultation and have agreed to their name being published:

• SSIR Partners Ltd
• UBT (EU) Ltd
• Personal Assurance Services Limited
• Golden Charter Limited
• City Hive
• Employers' Initiative on Domestic Abuse
• MSCI Limited
• Affinity
• Pinsent Masons
• Allianz UK
• Hymans Robertson LLP
• National Franchised Dealers Association
• Capita
• Cartlidge Morland
• Compare the Market
• Phoenix Group Managed Services
• Consumer Credit Trade Association (CCTA)
• Employment Lawyers Association (ELA)
• Royal Bank of Canada
• Vanquis Banking Group
• British Insurance Brokers' Association (BIBA)
• Diversity Project
• In Partnership
• Building Societies Association (BSA)
• The Society of Lloyds
• London & International Insurance Brokers' Association (LIIBA)
• Resolve Human Resources Limited
• SolasOS
• Gallagher
• Irish League of Credit Unions (ILCU)
• Simmons and Simmons LLP
• Personal Investment Management & Financial Advice Association (PIMFA)
• The Investment & Life Assurance Group (ILAG)
• City HR Association
• Lloyd's Market Association (LMA)
• Howden Group
• European Leveraged Finance Association (ELFA)
• Hargreaves Lansdown
• Association of Financial Mutuals (AFM)
• Chartered Insurance Institute (CII)
• Legal and General (L&G)
• UK Finance
• Lloyds Banking Group plc
• The Investing and Saving Alliance (TISA)
• NewDay
• Bloomberg LP
• Willis Limited
• Squire Patton Boggs (UK) LLP
• TP ICAP
• The Investment Association (The IA)
• The Broker Club
• Lewis Silkin LLP
• The Alternative Investment Management Association (AIMA)
• Marsh Ltd
• Shield FC
• The International Underwriting Association (The IUA)
• Standard Chartered Bank
• City of London Law Society Regulatory Law Committee
• Finance & Leasing Association (FLA)
• Association of British Insurers (ABI)

We are prohibited from disclosing the names of the respondents where these have asked that their response remains confidential. This is because we consider that the information has been received by the FCA for the purposes of, or in the discharge of, its functions under the Financial Services and Markets Act 2000 (“FSMA”).  Such information constitutes ‘confidential information’ as defined in section 348 of FSMA and is exempt from disclosure under section 44(1) (Prohibitions on disclosure) of FOIA.  Please refer to Annex B for full details of why this exemption applies.

3.     A list of meetings held with organisations concerning CP25/18 and minutes of those meetings.

Section 44 (Prohibitions on Disclosure)

Section 44(1)(a) of FOIA states that information is absolutely exempt from disclosure if this is prohibited by law. Section 348 of FSMA restricts the FCA from disclosing 'confidential information' it has received in the course of carrying out its public function. FSMA allows exceptions to this in a few specific circumstances, but none of these apply to this request.

Confidential information here is defined as non-public and non-anonymised information involving a person's business or other affairs, which the FCA received in the course of carrying out its public function.

As mentioned, the information you requested is confidential information under this provision.  If we disclosed it we would be in breach of section 348 of FSMA, which would be a criminal offence.

Section 44 is an ‘absolute’ exemption and so it is not necessary to balance the public interest for and against disclosing the information.