10th DECEMBER 2015 // Renaissance Hotel, BRUSSELS (BE)
Vania Franceschelli FECIF Board Member & ANASF Executive Committee Member
Product governance requirements will lead to greater quality of advice
Product governance requirements represent one of the most outstanding innovations of MiFID II, aiming at ensuring that firms which manufacture and distribute financial instruments act in the clients’ best interests during all the stages of the product life-cycle. While these new requirements cover a broad range of topics, on 2nd June 2017 ESMA has adopted specific guidelines which mainly address the “target market assessment”, considering this issue one of the most important aspects in order to ensure a consistent application of MiFID II provisions. Prior to the adoption of these guidelines, ESMA published a Consultation Paper, to which both FECIF and Anasf (the national association representing financial advisors in Italy) responded.
The ESMA guidelines are an important step in the direction of enhanced investor protection and regulatory convergence. In this sense, we can completely subscribe to the new guidelines when they establish that target market identification should not solely rely on quantitative criteria, but needs to be based on sufficient qualitative considerations as well (e.g. customer satisfaction). Similarly, the list of five categories to be used as a basis for identifying the target market can be read as a synopsis of good market practices...
The European Federation of Financial Advisers and Financial Intermediaries (FECIF) was chartered in June 1999 for the defence and promotion of the role of financial advisers and intermediaries in Europe.
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