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Insights
Jul 04, 2025
Jul 04, 2025
The long-awaited FCA paper on non-financial misconduct – was it worth the wait?
On 2 July 2025, the FCA published a further consultation paper on “tackling non-financial misconduct in financial services”. The industry has been eagerly awaiting publication of this paper, in the hope that it will address the current lack of clarity resulting from the tension between the total lack of guidance about non-financial misconduct currently in the FCA’s handbook, and the regulator’s regular assertions that non-financial misconduct is relevant to individuals’ fitness and propriety and their Individual Conduct Rules compliance.
The consultation paper, unconventionally, includes a short policy statement in which completed rule changes are published, as well as revised draft Handbook guidance (for consultation and feedback) concerning non-financial misconduct. This draft Handbook guidance replaces the draft guidance previously published in September 2023, in CP 23/20.
News
Jul 03, 2025
Jul 03, 2025
BCLP advises banking pool on financing Arkolia’s solar portfolio
Insights
Jul 03, 2025
Jul 03, 2025
JCT Target Cost Contract, 2024 Edition: first impressions
In this Insight, first published in PLC, Partner Shy Jackson considers the JCT's Target Cost Contract, 2024 Edition (TCC 2024), a new addition to its 2024 Edition contract suite that reflects the wider industry trend towards collaborative contracting. Thr article explores how the TCC 2024, based on the JCT Design and Build Contract 2024 (DB 2024), seeks to align the commercial interests of employers and contractors through the target cost mechanism. It examines the key new concepts of Allowable Cost, the Contract Fee, and the Adjusted Target Cost and how these elements combine to calculate the Difference Share, the pain/gain mechanism that incentivises collaboration and cost efficiency. It explores the various choices parties must make regarding the contract's operation, such as the timing of the Difference Share calculation and the potential use of the associated Target Cost Sub-Contract, 2024 Edition (TCCSub 2024) and highlights the practical implications for parties, such as the need for open-book accounting and robust record-keeping. Further, it contrasts the TCC 2024 with the equivalent target cost option under the NEC suite of contracts.