On 13 September 2017, JWG held their third Client Management Special Interest Group (CMS), with attendees from over a dozen buy-side, sell-side and technology firms meeting to discuss existing issues on cost and charges disclosure under MiFID II and PRIIPs obligations.  The meeting was a productive one, whereby participants expressed concerns on the following areas:


A granular understanding of the several types of costs and charges is important for all market participants.  These can have a substantial effect on investors’ returns (see graph below) and, if disclosed effectively, should facilitate market efficiency.  With this in mind, regulators have gone to considerable lengths to implement all the necessary requirements related to the disclosure of all costs and charges


Introduction With less than 5 months left before the deadline for MiFID II on 3 January 2018, firms are still grappling with the implementation of MiFID II.  One key area is the new product governance framework which has been enacted with the objective of ensuring that firms act in the best interests of their clients


Not long now – in less than 6 months’ time – both MiFID II and PRIIPs will become effective across EU Member States. ESMA recently published a Q&A on MiFID II and MiFIR investor protection topics in which 14 new questions were added. These include new Q&As on costs and charges in relation to the


On 17 January, ESMA published advice received from the Securities and Markets Stakeholder Group (SMSG) in relation to the consultation on MiFID II product governance.  This CP was released on 5 October 2016 and it set out to create guidelines relating to the target market assessment.  The SMSG established a working group with the specific


A busy December for financial regulation!

Never mind a busy December, all in all, it was a busy year for financial regulation as shown in one of our previous articles, as 384 regulatory documents were captured and uploaded in our trade and transaction RegDelta library. MiFID II Before Christmas, we saw ESMA publish many documents much like in January 2016 with


Best Execution: How compliant are NCAs now?

On 11 January 2017, ESMA released its follow-up to the peer review on best execution which came out in February 2015.  With significant improvement by many NCAs since the 2015 review, the follow-up reads as a far more positive report, with optimism for further development in the future.  Although certainly not perfect, it reveals that


Getting MiFID II right the first time

Transparency is the cornerstone of MiFID II. Whether it’s pricing, product or process transparency, participants will need to pull back the curtains to make more information public regarding the nature of their operations, products and services. Consequently, investment firms will need to know more about their clients than ever before, with very little margin for


In April 2016, European Supervisory Authorities (ESA) submitted a draft Regulatory Technical Standards (RTS) for Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation, focusing on the requirements of key information documents (KID).  Despite the KID RTS being endorsed by the EU Commission, the European Parliament – in a surprising move – rejected the draft.  It


On the 14 September 2016 there was a staggering majority vote against the EU Commission’s Regulatory Technical Standards (RTS) for the PRIIPS key information document (KID), at 602 to 4, with 12 abstentions. The rejection by the Parliament of the implementation rules proposed by the Commission is unprecedented in the financial markets, and now it