AMIC response to the ESMA consultation paper ‘Guidelines on certain aspects of the MiFID II suitability requirements’
27 April 2022
In its response, AMIC highlighted the implementation challenges of the 2 August application date from product manufacturer, distributor and end-investor perspectives;
AMIC submitted its response to the ESMA consultation paper on
the ‘Guidelines on certain aspects of the MiFID II suitability
requirements’. In its response, AMIC highlighted the implementation
challenges of the 2 August application date from product manufacturer,
distributor and end-investor perspectives; and made specific suggestions
on the proposed draft guidelines to help the clients assessment process
and align the final guidelines to the Delegated Act. Most critically,
AMIC recommended a no action letter from the ESAs advising NCAs to not
prioritize supervisory action towards implementing sustainability
preferences in the MiFID II suitability assessment as of 2 August
2022. This forbearance period would allow firms to implement the final
guidelines avoiding the burden and risks arising from double
implementation; as well as wider availability of products to offer to
clients following their suitability assessment as the necessary
(corporate related) data should become available and more reliable in
2025 the earliest.
ICMA
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