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Global Trustee and Fiduciary Services News and Views | MiFID II Special Edition 2016
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Q17 Have you engaged across your
distribution chain to ensure that “target
market” requirements can be met?
71% of asset managers confirm that
they have engaged their distribution
chain to ensure that the “target market”
requirements can be met.
Q18 Has this engagement required a better
understanding on your part, as the product
manufacturer, of how the distribution of
your product is achieved?
While 33% of those questioned advise that
this was not an applicable consideration,
an equal number of asset manages confirm
the engagement has led to a better
understanding of how the distribution
of their product is achieved.
Interestingly, a third of respondents also advise
the engagement has not required a better
understanding, although specific reasons are
not provided as part of the responses.
Q19 Will your firm be looking to use any
industry association templates or guidance
to assist you in meeting the target market
requirements?
Three-quarters of respondents confirm that
they will be looking to utilise an industry
association template and/or guidance to
help them in meeting their target market
requirements.
Q20 How long have you been working on
your MiFID II implementation plans?
Less than 12 months
12 month to 18 months
18 months to 3 years
0% 10% 20% 30% 40% 50%
Q21 Will your firm be ready for the MiFID II/
MiFIR go live date in 2018?
With the exception of one response that
marked as uncertain, all other asset
managers confirm that they will be ready
for the revised 2018 implementation date.
Q22 Have you included other legislative
packages or considerations as part of
your MiFID II/MiFIR project?
Asset managers have also been questioned
on whether, as part of their MiFID II/
MiFIR projects, they have considered other
legislative packages.
Many advise they have not, but the areas
identified by asset managers that have been
included are PRIIPs Costs and Charges (71%),
Brexit: Potential Implications for MiFID II
Passporting Rights (71%), and the Market
Abuse Regulation (50%).
In conclusion
The survey results indicate that firms are still at
varying stages in their implementation planning
and decision-making. Why some of the firms
are not yet in a position to have made any final
decisions about how they will deal with certain
aspects of the requirements is most likely due
to the fact that there have been continuing
delays in finalising the critical details that will
be contained in Level 2 technical standards and
Level 3 Q&A. These are necessary before some
of the final puzzle pieces can be slotted in.
We would like to thank all respondents who
contributed to our survey. We hope that they, as well
as all our readers, find the collated results useful.
Amanda Hale
Head of Regulatory Services
Trustee and Fiduciary Services, Citi
Andrew Newson
Senior Fiduciary Technical Analyst, Citi
General Data Protection
PRIIPs (Costs and Charges)
Market Abuse Regulation
Short Selling Regulation
Securities Financing
Benchmark Regulation
Brexit: Potential Implication
Yes
No
0% 20% 40% 60% 80% 100%