As requested by the FCA, this note contains a summary of concerns around applicability of Article 12(3)(b) of the Delegated Directive in connection with the investor education process when pre-deal research is produced by independent financial analysts in the research departments of firms.
The summary adresses the applicability in connection with the investor education process when pre-deal research is produced by independent financial analysts in the research departments of firms which also underwrite or place the initial public offering and the need for clarification as to the treatment of independent pre-deal research reports and any accompanying investor education meetings discussing those reports under the MiFID II regime.
Following the discussion at a meeting with the FCA on 30th January, AFME requests that the FCA provide additional clarification on whether independent pre-deal research and accompanying investor education meetings as currently provided in the market could be designated as a minor non-monetary benefit under the requirements of MiFID II and the list of acceptable minor non-monetary benefits as set out in the proposed text of COBS 6.1A.5A.
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