(This note is not part of the Instrument and does not purport to be a legal interpretation.)

These Regulations give partial effect to Directive (EU) 2019/2034 of the European Parliament and of the Council of 27 November 2019 on the prudential supervision of investment firms (the "Investment Firms Directive"). The Investment Firm Directive (IFD) and Regulation (IFR) puts in place a new prudential framework for Investment Firms authorised under Directive 2014/65/EU, the Markets in Financial Instruments Directive (MiFID II). The specific rules that will apply to a particular investment firm will depend on a firm’s classification under this new prudential framework.