The FCA and MiFID II: Early Considerations for Asset Managers
Although it is not limited to asset managers, the FCA ‘s Discussion Paper on developing its approach to implementing the MiFID II conduct of business requirements (“DP 15/3”) published in late March, highlights certain aspects of MiFID II which will be of particular interest to asset managers as they prepare for MiFID II implementation.
The following, in our view, represent the most important areas for asset managers in DP 15/3:
- Commissions and other benefits for discretionary investment managers
- Client categorisation and the treatment of local public authorities and municipalities
- Recording of telephone conversations and electronic communications
- Costs and charges disclosure
- Revised inducements standards generally
- Complex and non-complex products and application of the appropriateness test
In some cases, the FCA seeks comment. In others, it merely provides comment – almost akin to guidance. Moreover, certain MiFID II conduct of business requirements, such as those governing product governance, are not mentioned in the context of asset management – although, product goverannce is mentioned in other contexts. DP 15/3 does not, therefore, cover all topics. It is, however, a useful, albeit early indicator, of the FCA’s views and highlights areas that asset managers need to be considering as part of their MiFID II implementation programmes.
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