Eversheds speaks to Sturgeon Ventures regarding the FCA and MIFID II for investment managers

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.
To read the full article, download the PDF:

 
 
 
 
For further guidance please:
Email:  ronaldpaterson@eversheds.com or andrewhenderson@eversheds.com
Visit Evershed’s Website: http://www.eversheds.com/

Sturgeon Ventures Background Information

Sturgeon Ventures are the most established Regulatory Incubator,a trusted partner and venture catalyst.  Providing nurturing and bespoke solutions, also known as a Regulatory Umbrella, Regulatory Hosting or Regulatory Ecosystem.
Sturgeon Ventures has incubated people and firms since 1999 and has been a family office wealth advisor since 1998.  Sturgeon Ventures are Authorised and Regulated by the FCA and provide regulatory umbrella services.
We have been nominated and won many awards including most recently Finance Awards Most Trusted FCA Regulatory Incubator 2104, ACQ MAGAZINE Business Incubator of the year 2104 and Venture Capitalist of the Year at the 2014 M&A Awards.