German Ministry of Finance position papers have started an important discussion amongst market participants, investors and trade associations, well ahead of the upcoming MiFID 2 refit. The purpose of this EBF note is to contribute to the discussion by identifying some of the issues that EBF members consider to be particularly important for the future well-functioning of the EU securities secondary markets.
The EBF is supportive of further consistency in EU regulation (in particular MIFID, PRIIPS and UCITS). The EBF would also like to stress the need for amendments to be evidence-based and for firms to begiven a sufficiently long implementation period in order to adapt to the new rules. Finally, the EBF supports the need for an overall assessment of MiFID 2/MiFIR to be conducted according to the principle of proportionality.
Wholesale clients should be exempted from the information requirements in MiFID 2 whilst allowing individual clients to opt down and be treated as retail clients for a particular service or transaction. With specific reference to the disclosure of the costs and charges’ requirements, EBF believes it would be more balanced to provide a full exemption from the ex-ante disclosure.
EBF supports the proposal to allow investment firms to provide ex-ante cost information under the same conditions as set out in Article 25 (6) MiFID 2. The article entitles the provision of a suitability report immediately after the transaction under certain conditions and without having to delay the transaction.
Regarding market structure, EBF supports the improvement of data quality and reporting requirements and would highlight, too, the issue of raising data costs.
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