The Financial Conduct Authority (FCA) has said “time will tell” whether the UK government will allow passporting of US-listed ’40-Act’ ETFs under the Overseas Fund Regime (OFR).
Speaking at ETF Stream’s ETF Ecosystem Unwrapped 2025 event, Mhairi Jackson, manager for funds and asset management policy at the FCA noted in order to extend the OFR to US-listed ETFs the FCA would need to examine how each US ETF would compare to its equivalent UK structure.
“We would be doing a comparison to a UCITS fund structure and then we would need to work out whether that was providing the equivalent investor protection,” she explained.
Jackson went on to note this may present some difficulties given the marked divergence of EU UCITS structures from their US counterparts.
“We can definitely see the attraction of being able to offer US ETFs to US expats in the UK.”
The OFR is a UK regulatory…
