Responding to the
CESR consultation on inducements under
MiFID the
ZKA strongly welcomes the fact that
CESR is no longer pursuing the approach of a proportionality between the amount of the inducement and the value of the investment service. It also welcomes that that
CESR no longer requires a direct relationship between the individual inducement and the enhancement of quality of a particular investment service provided to a customer as this would have caused in practice hardly solvable problems concerning the proof and the documentation of the “enhancement-test”.
“Overall, the second consultation paper accordingly earns our emphatic support”, ZKA states pointing out a few items that would require further clarification.
ZKA paper
© ZKA - Zentraler Kreditausschuss
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