MiFID II Delegated Acts - Part 1

Final Rules - Part 1 - Further details to be released later.

http://ec.europa.eu/transparency/regdoc/rep/3/2016/EN/3-2016-2031-EN-F1-1.PDF

Key Points - Initial Reaction

  1. CSAs survive and can fund RPAs.

  2. Monetary Research Budgets Required.

  3. Asset owners must be informed of their respective portion in advance. New
    language appears to have potentially increased the granularity of research budget reporting.

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    (c) where an investment firm makes use of the research payment account, it shall provide the following information to clients: (i) before the provision of an investment service to clients, information about the budgeted amount for research and the amount of the estimated research charge for each of them. (ii) annual information on the total costs that each of them has incurred for third party research.

  4. There is no specific exemption of the research budgeting rules for non-equity asset classes in this document.