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1 EFAMA Position Paper on the European for a Directive of the European Parliament and of the Council on markets in Financial Instruments Repealing Directive 2004/39/EC of the European Parliament and of the Council Recitals... 3 Recital Recital Recital Recital 48 a (new)... 6 TITLE I DEFINITIONS AND SCOPE... 6 New Article 4, (30) MiFID... 7 TITLE II AUTHORISATION AND OPERATING CONDITIONS FOR INVESTMENT FIRMS... 7 CHAPTER 1 CONDITIONS AND PROCEDURES FOR AUTHORISATION... 7 Article 16 paragraph 7/ Amendment 53 of the Ferber Draft Report... 7 Article Article CHAPTER II OPERATING CONDITIONS FOR INVESTMENT FIRMS Section 2 Provisions to ensure Investor Protection Article 24 paragraph 5 Subparagraph ii /Amendment 70 of the Ferber s Draft Report Article 24 Paragraph 6 and Recital 52/ Amendment 71 and 16 of the Ferber Draft Report. 12 Recital Article 25 Paragraph 3 Letter a Indent iv and Recital Recital CHAPTER III RIGHTS OF INVESTMENT FIRMS Article Article New Article 40a MiFID CHAPTER IV Provision of Services by Third Country firms Section 1 Provision of Services with establishment of a branch rue Montoyer 47, B 1000 Bruxelles Fax e mail :

2 2 EFAMA comments on on MIFID Recital 72 MiFID Recital 73 MiFID Recital 74 MiFID Article 41 Para Article 41 Para Article 41 Para New Article 41a MiFID Member State of Reference Article TITLE III Regulated Markets Article TITLE V Data reporting services Section 1 Authorisation procedures for data reporting services providers Article Article Article Article Article Section 2 Conditions for approved publication arrangements (APAs) Article 66 Par Article 66 Paragraph Section 3 Conditions for consolidated tape providers (CTPs) Article 67 Par Section 4 Conditions for approved reportings mechanisms (ARMs) Article TITLE VII CHAPTER 3 FINAL PROVISIONS Article

3 3 EFAMA comments on on MIFID EFAMA is the representative association for the European investment management industry. EFAMA represents through its 27 member associations and 57 corporate members approximately EUR 14 trillion in assets under management of which EUR 8 trillion was managed by approximately 54,000 funds at the end of For more information about EFAMA, please visit Comments and Proposed Amendments EFAMA congratulates MEP Markus Ferber for the excellent, high quality and enormous work done and for the publication of his draft report on the Commission s proposal for MIFID/R. EFAMA largely agrees with the Rapporteur s Draft Report, however would like to propose the following comments and amendments: Recitals Recital 44 (44) The use of trading technology has evolved significantly in the past decade and is now extensively used by market participants. Many market participants now make use of algorithmic trading where a computer algorithm automatically determines aspects of an order with minimal or no human intervention. A specific subset of algorithmic trading is high frequency trading where a trading system analyses data or signals from the market at high speed and then sends or updates large numbers of orders within a very short time period in response to that analysis. High frequency trading is typically done by the traders using their own capital to trade and rather than being a strategy in itself is usually the use of sophisticated technology to implement more traditional trading strategies such as market making or arbitrage. (44) The use of trading technology has evolved significantly in the past decade and is now extensively used by market participants. Many market participants now make use of algorithmic trading where a computer algorithm automatically determines aspects of an order with minimal or no human intervention. Algorithmic trading is based on trading parameters or limits or ways to manage their order after submission that shall ensure that the strategy posts firm quotes at competitive prices with the result of providing liquidity on a regular and ongoing basis to these trading venues at all times, regardless of prevailing market conditions A specific subset of algorithmic trading is high frequency trading where a trading system analyses data or signals from the market at high speed, typically in milliseconds or microseconds, and then sends or updates large numbers of orders within a very short time period in response to that analysis. High frequency trading is typically done by the traders using their own capital to trade and

4 4 EFAMA comments on on MIFID rather than being a strategy in itself can often involve the use of sophisticated technology to implement more traditional trading strategies such as market making or arbitrage. Both the original and the proposed amended text are raising some concerns within EFAMA as the two versions are trying to address two issues here, which should be answered separately and more clearly: (1) algorithms are used for best execution purposes and for HFT; and (2) algorithms may be proprietary or purchased, i.e. one may or may not have access to the computer code and the inner working of the algorithm (this is true for both best execution algorithms and HFT algorithms). The current provisions on algorithmic trading provisions are far too broad and would capture many firms that do not use High Frequency Trading. Whereas we acknowledge the need for proper systems and controls and business continuity, investment managers should be carved out, as they undertake only client business and initiate transactions on behalf of clients. Every computer program uses algorithms. Investment managers may also use algorithms to execute orders, in order to achieve best execution for their clients and manage market impact in a timeefficient way. Mr. Ferber defines HFT as trading at speeds where physical latency becomes the determining factor in the time taken to execute. We are concerned that those criteria alone would lead to more opacity We don t believe the wording proposed would catch standard algorithmic trading as it keeps the continuous liquidity provision obligation (art 17.3) but, importantly, only for firms using HFT strategies as per new definition. Therefore we propose the above amendment in addition to Mr. Ferber s proposed text. Recital 46 (46) The use of trading technology has increased the speed, capacity and complexity of how investors trade. It has also enabled market participants to facilitate direct access by their clients to markets through the use of their trading facilities, through direct electronic access or sponsored and direct market access. Trading technology has provided benefits to the market and market participants generally such as wider participation in markets, increased liquidity,

5 5 EFAMA comments on on MIFID narrower spreads, reduced short term volatility and the means to obtain better execution of orders for clients. Yet, this trading technology also gives rise to a number of potential risks such as an increased risk of the overloading of the systems of trading venues due to large volumes of orders, risks of algorithmic trading generating duplicative or erroneous orders or otherwise malfunctioning in a way that may create a disorderly market. In addition there is the risk of algorithmic trading systems overreacting to other market events which can exacerbate volatility if there is a pre existing market problem. Finally, algorithmic trading or high frequency can lend itself to certain forms of abusive behavior if misused. EFAMA agrees with Mr. Ferber proposed amendment. Recital 47 (47) These potential risks from increased use of technology are best mitigated by a combination of specific risk controls directed at firms who engage in algorithmic or high frequency trading and other measures directed at operators of trading venues that are accessed by such firms. It is desirable to ensure that all high frequency trading firms be authorized when they are a direct member of a trading venue. This should ensure they are subject to organizational requirements under the Directive and are properly supervised. (47) These potential risks from increased use of technology are best mitigated by a combination of specific risk controls directed at firms who engage in algorithmic or high frequency trading and other measures directed at operators of all trading venues that are accessed by such firms. It is desirable to ensure that all high frequency trading firms be authorised when they are a direct member of a trading venue. This should ensure they are subject to organisational requirements under the Directive and are properly supervised. It is also appropriate to end the practice of sponsored access to avoid the risk that firms with insufficient controls in place create disorderly market conditions and to ensure that market participants can be identified and held accountable for any

6 6 EFAMA comments on on MIFID disorderly conditions for which they are responsible. EFAMA agrees with the. However, should a ban made mandatory, EFAMA considers that some further distinction must be brought in this recital. Direct Market Access should receive a different treatment than Sponsored Access. It is important to distinguish the different direct electronic access (DEA). DEA include Direct Market Access (DMA) and Sponsored Access (SA). ESMA gives a definition of the following elements: Direct Market Access (DMA) is an arrangement through which an investment firm that is a member/participant or user of a trading platform permits specified clients (including eligible counterparties) to transmit orders electronically to the investment firm s internal electronic trading systems for automatic onward transmission under the investment firm s trading ID to a specified trading platform. Sponsored access (SA) is an arrangement through which an investment firm that is a member/participant or user of a trading platform permits specified clients (including eligible counterparties) to transmit orders electronically and directly to a specified trading platform under the investment firm s trading ID without the orders being routed through the investment firm s internal electronic trading systems EFAMA agrees with the aim of the proposed amendment but strongly recommend to reconsider the scope by using the defined activity in accordance with the really pursued goal. Recital 48 a (new) EFAMA supports the provisions on fair access between venues and clearing houses, all of which should improve market resilience, also through non discriminatory access to and obligation to license benchmarks, as stated in Mr. Ferber s report. TITLE I DEFINITIONS AND SCOPE

7 7 EFAMA comments on on MIFID New Article 4, (30) MiFID 30) "Algorithmic trading" means trading in financial instruments where a computer algorithm automatically determines individual parameters of orders such as whether to initiate the order, the timing, price or quantity of the order or how to manage the order after its submission, with limited or no human intervention. This definition does not include any system that is only used for the purpose of routing orders to one or more trading venues or for the confirmation of orders; Algorithmic trading means trading in financial instruments where a computer algorithm automatically determines individual parameters of orders such as whether to initiate the order, the timing, price or quantity of the order or how to manage the order after its submission, with limited or no human intervention. This definition does not include any system that is only used for the purpose of routing orders to one or more trading venues or for the confirmation of orders or to execute client orders directly or for the purpose of complying with Article 27 (best execution) or to fulfil any legal obligation through the determination of a parameter of the order; Mr. Ferber proposes (amendment 42) to include in the definition of algorithmic trading best execution algorithmic trading. We prefer the Commission s original proposal to exclude best execution algorithms. The proposed definitions would offer too many options for arbitrage by HFT firms. Therefore, we proposed the above mentioned language together with a proposal for a new Art MiFID TITLE II AUTHORISATION AND OPERATING CONDITIONS FOR INVESTMENT FIRMS CHAPTER 1 CONDITIONS AND PROCEDURES FOR AUTHORISATION Article 16 paragraph 7/ Amendment 53 of the Ferber Draft Report In Ferber Draft Report Amendment 53 adds the option of adequate documentation instead of registration. EFAMA welcome this second option, however considers that portfolio management services are not covered by the provisions in art. 16 Paragraph 7. In any case, calls conducted with broker/dealers will be already recorded by the broker/dealers they trade with, and records are duly kept by portfolio managers. However, the provisions would apply to fund distributors with direct client contact, and here EFAMA is concerned that the cost of telephone recording requirements for small distributors or regional

8 8 EFAMA comments on on MIFID banks with branch networks could prove exceedingly high. It should be recognized that recordkeeping is already required under MiFID, and a written confirmation of the transaction is sent to the client. Furthermore, under the UCITS Directive, recording of subscription and redemption orders (and written confirmation) is required from product providers, and under AIFMD such requirement will be extended to all funds distributed in the European Union. Organizational requirements 7. Records shall include the recording of telephone conversations or electronic communications involving, at least, transactions concluded when dealing on own account and client orders when the services of reception and transmission of orders and execution of orders on behalf of clients are provided. Records of telephone conversation or electronic communications recorded in accordance with sub paragraph 1 shall be provided to the clients involved upon request and shall be kept for a period of three years. DELETE Orders relating to investment fund subscriptions and redemptions should be clearly exempt from recording requirements, as they do not raise market abuse issues and recordkeeping and client confirmation are already required. In particular, the transmission of orders from final distributors/intermediaries to regional or global distributors part of the fund distribution chain (often MiFID licensed firms belonging to the same group as the fund management company) should be exempt from such requirements, as it neither entails any direct contact with investors, nor can it give rise to market abuse. Article 17.3 Algorithmic trading 3. An algorithmic trading strategy shall be in continuous operation during the trading hours of the trading venue to which it sends orders or through the systems of which it executes transactions. The trading parameters or limits of an algorithmic trading strategy shall ensure that the strategy posts firm quotes at competitive prices with the result of providing 3. An investment firm whose principal activity is to post quotes (market making) using an algorithmic trading strategy shall ensure that it remains in continuous operation during the trading hours of the trading venue to which it sends orders or through the systems of which it executes transactions. The trading parameters or limits of such an algorithmic trading strategy

9 9 EFAMA comments on on MIFID liquidity on a regular and ongoing basis to these trading venues at all times, regardless of prevailing market conditions. shall ensure that the strategy posts firm quotes at competitive prices with the result of providing liquidity on a regular and ongoing basis to these trading venues at all times, regardless of prevailing market conditions. The efforts to address HFT are very useful. Whilst there are clearer definitions between Algorithmic trading and High Frequency trading, there are still some aspects were the proposal could lead to confusion. Hence EFAMA proposes the above language which would also support liquidity in the Markets.

10 10 EFAMA comments on on MIFID Article 17.4 Organisational requirements 4. An investment firm that provides direct electronic access to a trading venue shall have in place effective systems and controls which ensure a proper assessment and review of the suitability of persons using the service, that persons using the service are prevented from exceeding appropriate pre set trading and credit thresholds, that trading by persons using the service is properly monitored and that appropriate risk controls prevent trading that may create risks to the investment firm itself or that could create or contribute to a disorderly market or be contrary to Regulation (EU) No [MAR] or the rules of the trading venue. The investment firm shall ensure that there is a binding written agreement between the firm and the person regarding the essential rights and obligations arising from the provision of the service and that under the agreement the firm retains responsibility for ensuring trading using that service complies with the requirements of this Directive, the Regulation (EU) No [MAR] and the rules of the trading venue. 4. Investment firms shall not provide sponsored access to a trading venue. Please also consider the amendment to Recital 47. EFAMA agrees with the Commission s proposal. However, should a ban be made mandatory, EFAMA members understand and agree with the proposed ban as long as it is well defined and is applied to sponsored access. It is important to distinguish the different direct electronic access (DEA). DEA include Direct Market Access (DMA) and Sponsored Access (SA). ESMA gives a definition of the following elements: (1) Direct Market Access (DMA) is an arrangement through which an investment firm that is a member/participant or user of a trading platform permits specified clients (including eligible counterparties)21 to transmit orders electronically to the investment firm s internal electronic trading systems for automatic onward transmission under the investment firm s trading ID to

11 11 EFAMA comments on on MIFID a specified trading platform. DMA provides the utilization of best execution algorithm for the final interest of the client. (2) Sponsored access (SA) is, on the other hand, an arrangement through which an investment firm that is a member/participant or user of a trading platform permits specified clients (including eligible counterparties) to transmit orders electronically and directly to a specified trading platform under the investment firm s trading ID without the orders being routed through the investment firm s internal electronic trading systems. CHAPTER II OPERATING CONDITIONS FOR INVESTMENT FIRMS Section 2 Provisions to ensure Investor Protection Article 24 paragraph 5 Subparagraph ii /Amendment 70 of the Ferber s Draft Report EFAMA agrees with the Rapporteur and the Commission view that it is necessary to improve investor protection and strengthen provisions relating to advice. Intermediaries providing investment advice should make clear the basis on which the advice is provided, to enhance transparency to investors and enable them to better assess the quality of the service. Transparency to investors and correct enforcement are key to the provision of good quality advice. Our members fully support clarity and disclosure about the selection and assessment of products, as well as regarding remuneration of advisers. At the same time, they have a strong interest in maintaining choice of distribution channels for investors and are concerned that a ban on the acceptance of monetary inducements for advice provided on an independent basis will actually lead to a reduction in competition among distribution channels, and/or a reduction in the number of products offered by distributors. Several studies show that a large majority of retail clients are unwilling to pay for advice, and under a fee based model the current subsidization of advice to small retail clients will no longer be possible. Measures aiming at banning inducements are likely to reduce access to advice for retail investors, leading to a Union where only the wealthiest would be able to afford the luxury of a full range of investment options. More than ever, EU citizens need access to sound advice for long term investment, as both social security systems and companies are forced to cut back on pension provision, and pension fund returns suffer from the financial crisis. Further reducing access to advice is neither in the interest of retail investors, nor encourages savings accumulation and therefore a healthy growth of EU capital markets in the long term. Furthermore, the provisions in Para. 5 of Art. 24 for firms providing advice on an independent basis require the assessment of a sufficiently large number of financial instruments, and not limited to financial instruments issued or provided by entities having close links with the investment firm. It should be ensured that the simple use of an execution platform belonging to a group is not considered equivalent to the provision of the product, as this would prohibit the use of such

12 12 EFAMA comments on on MIFID execution platforms, which constitute purely an auxiliary service and do not threaten the independence of the adviser. In light of these reasons, we would therefore recommend deletion of art ii of the Commission Proposal as amended in the Ferber draft Report. 5. When the investment firm informs the client that investment advice is provided on an independent basis, the firm: (ii) shall not accept or receive fees, commissions or any monetary benefits paid or provided by any third party or a person acting on behalf of a third party in relation to the provision of the service to clients. DELETE In many Member States, distribution of financial products is either carried out by bank and insurance company linked financial groups, or by unrelated financial advisers. Such financial advisers are more likely to distribute products from product providers not related to a financial group, and could fulfill the requirements for the provision of independent advice. However, as such independent advisers are usually small, the prohibition to accept monetary inducements would weaken their economic viability, leading to a loss of many jobs in the industry and reducing competition among distribution channels to the detriment of end investors. As a result, access to products from product providers unrelated to large financial groups would also be reduced and the progress of open architecture in the European Union would be undermined. Article 24 Paragraph 6 and Recital 52/ Amendment 71 and 16 of the Ferber Draft Report EFAMA welcomes the amendments 71 and 16 of the Ferber Report where he substitutes the total ban of inducements with transparency. EFAMA does not consider that monetary inducements in the case of portfolio management should be banned entirely. We are not aware of evidence of market failure in this area that would warrant such a measure. Non monetary benefits such as soft commissions (broker research, financial analysis or pricing information systems) provide important assistance for asset managers in the process of taking investment decisions or transmitting orders for execution and are subject to MiFID Level 2 requirement that they enhance the quality of the service. EFAMA is therefore of the opinion that soft commissions should in any case be permitted in relation to portfolio management (in particular the provision of research bundled with brokerage services), as they are valuable to the industry as a

13 13 EFAMA comments on on MIFID whole, they help reduce fees to clients, and assist investment managers in providing a better service to their clients. Paragraph 6 rules out only fees, commissions or monetary payments, but Recital 55 could be interpreted as restricting the type of non monetary benefits a portfolio manager may receive (it refers to limited non monetary benefits as training on the features of the products ). 6. When providing portfolio management the investment firm shall not accept or receive fees, commissions or any monetary benefits paid or provided by any third party or a person acting on behalf of a third party in relation to the provision of the service to clients. 6. When providing portfolio management the investment firm shall not accept or receive fees, commissions or any monetary benefits paid or provided by any third party or a person acting on behalf of a third party in relation to the provision of the service to clients, except if: a) the client has been duly informed of such fees, commissions or monetary benefits before the provision of the relevant service; b) these fees, commissions or monetary benefits are to the ultimate benefit of the client. Recital 52 In order to give all relevant information to investors, it is appropriate to require investment firms providing investment advice to clarify the basis of the advice they provide, notably the range of products they consider in providing personal recommendations to clients, whether they provide investment advice on an independent basis and whether they provide the clients with the on going assessment of the suitability of the financial instruments recommended to them. It is also appropriate to require investment firms to explain their clients the reasons of the advice provided to them. In order to further define the regulatory framework for the provision of investment advice, while at the same time leaving choice to investment firms and clients, it is appropriate to establish the conditions for the provisions of this service when In order to give all relevant information to investors, it is appropriate to require investment firms providing investment advice to clarify the basis of the advice they provide, notably the range of products they consider in providing personal recommendations to clients, whether they provide investment advice and whether they provide the clients with the on going assessment of the suitability of the financial instruments recommended to them. It is also appropriate to require investment firms to explain their clients the reasons of the advice provided to them. In order to further define the regulatory framework for the provision of investment advice, while at the same time leaving choice to investment firms and clients, it is appropriate to establish the conditions for the provisions of this service when firms inform

14 14 EFAMA comments on on MIFID firms inform clients that the service is provided on an independent basis. In order to strengthen the protection of investors and increase clarity to clients as to the service they receive, it is appropriate to further restrict the possibility for firms to accept or receive inducements from third parties, and particularly from issuers or product providers, when providing the service of investment advice on an independent basis and the service of portfolio management. In such cases, only limited nonmonetary benefits as training on the features of the products should be allowed subject to the condition that they do not impair the ability of investment firms to pursue the best interest of their clients, as further clarified in Directive 2006/73/EC. clients of the acceptance or receipt of third party inducement. When providing portfolio management the investment firm shall not accept or receive fees, commissions or any monetary benefits paid or provided by any third party or a person acting on behalf of a third party in relation to the provision of the service to clients, except if: a) the client has been duly informed of such fees, commissions or monetary benefits before the provision of the relevant service; b) These fees, commissions or monetary benefits are to the ultimate benefit of the client. It should be clarified that monetary and non monetary benefits may continue to be received as long as they do not impair the ability of investment firms to pursue the best interest of their clients, as further clarified in Art. 26 of Directive 2006/73/EC. It is appropriate that either inducement be related to the client (as already done in some cases) or the client should be allowed to consent to them being kept by the portfolio manager. It must be noted that inducements kept by portfolio managers reduce the fees charged to investors. Should they be banned, fees would have to be increased as a result. The should be modified to allow for the rebating of monetary inducements to the client or to allow for payments to the portfolio manager, subject to client express consent. Article 25 Paragraph 3 Letter a Indent iv and Recital 53 There are not Ferber s amendments on art. 25 and Recital 53. The excludes structured UCITS from non complex financial instruments eligible for execution only services. EFAMA does not consider it appropriate, as UCITS are conceived as retail products, are very strictly regulated and provide a high degree of investor protection. UCITS are also very liquid (redemptions possible usually daily, but at least twice a month), do not involve any liability exceeding the acquisition cost, provide a very high level of disclosure to retail investors (which has been further improved with the introduction of the Key Investor Information Document under UCITS IV), are subject to stringent risk management rules and, above all, are designed to be well diversified. UCITS are also by far the most transparent financial instruments, and the recent introduction of the Key Investor Information Document (KIID) makes them even easier for retail investors readily to

15 15 EFAMA comments on on MIFID understand them. They therefore can easily fulfill all the requirements of Art. 38 of the current Level 2 Directive to fall within the definition of non complex instrument. We also note that UCITS are subject to pre approval by regulators, giving regulators the ability to challenge and seek further information from fund promoters if they think the overriding requirements relating to ease of understanding in Article 38 of the current level 2 directive and the provisions of the UCITS Directive, particularly those related to KIID disclosures, have not been met. Nonetheless, even if structured UCITS are no longer defined as automatically non complex for execution only purposes, they (together with other financial instruments subject to carve out in Letter a of Para. 3, such as non UCITS fund shares) should remain subject to the test in Art. 38 Level 2 Directive. EFAMA is concerned by the lack of clarity of the new wording in Art. 25 (6), which might be interpreted as excluding completely the possibility for the carved out instruments to be considered as non complex (eliminating the need for Art. 38 at Level 2). The test in Art. 38 Level 2 remains appropriate and Level 1 text must be modified clearly to allow for its application to structured UCITS. ESMA Guidelines for the assessment of financial instruments incorporating a structure which makes it difficult for the client to understand the risk involved as required by Para. 7 of Art. 25 can be useful, but should rather be included in Level 2 text as an addition to Art. 38, as they clearly refer to the fourth criterion of the article, and should replicate the current Art. 38 of the Level 2 Directive. Non UCITS funds in general (including shares in non UCITS admitted to trading on a regulated market) should also continue to be subject to the test in Art. 38 of Level 2 MiFID, and not be considered automatically complex. 3. Member States shall allow investment firms when providing investment services that only consist of execution and/or the reception and transmission of client orders with or without ancillary services, with the exclusion of the ancillary service specified in Section B (1) of Annex 1, to provide those investment services to their clients without the need to obtain the information or make the determination provided for in paragraph 25 where all the following conditions are met: a) the services referred to in the introductory part relate to any of the following financial instruments: (iv) shares or units in UCITS excluding 3. Member States shall allow investment firms when providing investment services that only consist of execution and/or the reception and transmission of client orders with or without ancillary services, with the exclusion of the ancillary service specified in Section B (1) of Annex 1, to provide those investment services to their clients without the need to obtain the information or make the determination provided for in paragraph 25 where all the following conditions are met: a) the services referred to in the introductory part relate to any of the following financial instruments: (iv) shares or units in UCITS

16 16 EFAMA comments on on MIFID structured UCITS as referred to in Article 36 paragraph 1 subparagraph 2 of Commission Regulation 583/2010; Recital 53 Investment firms are allowed to provide investment services that only consist of execution and/or the reception and transmission of client orders, without the need to obtain information regarding the knowledge and experience of the client in order to assess the appropriateness of the service or the instrument for the client. Since these services entail a relevant reduction of clients' protections, it is appropriate to improve the conditions for their provision. In particular, it is appropriate to exclude the possibility to provide these services in conjunction with the ancillary service consisting of granting credits or loans to investors to allow them to carry out a transaction in which the investment firm is involved, since this increases the complexity of the transaction and makes more difficult the understanding of the risk involved. It is also appropriate to better define the criteria for the selection of the financial instruments to which these services should relate in order to exclude the financial instruments, including collective investment in transferable securities (UCITS), which embed a derivative or incorporate a structure which makes it difficult for the client to understand the risk involved. Investment firms are allowed to provide investment services that only consist of execution and/or the reception and transmission of client orders, without the need to obtain information regarding the knowledge and experience of the client in order to assess the appropriateness of the service or the instrument for the client. Since these services entail a relevant reduction of clients' protections, it is appropriate to improve the conditions for their provision. In particular, it is appropriate to exclude the possibility to provide these services in conjunction with the ancillary service consisting of granting credits or loans to investors to allow them to carry out a transaction in which the investment firm is involved, since this increases the complexity of the transaction and makes more difficult the understanding of the risk involved. It is also appropriate to better define the criteria for the selection of the financial instruments to which these services should relate in order to exclude the financial instruments which embed a derivative or incorporate a structure which makes it difficult for the client to understand the risk involved. Importantly, the very successful UCITS brand could suffer damage in the eyes of non EU regulators and investors if some UCITS were no longer considered automatically non complex, as they may be seen as unsuitable for retail investors. European investors confidence in UCITS might also be affected. Complexity is not equal to risk. On the contrary, many of the UCITS features (including special strategies and techniques, also used in structured UCITS) reduce risks for investors which are high in

17 17 EFAMA comments on on MIFID plain vanilla financial instruments such as stocks and bonds. What is relevant for retail investors is their understanding of the product s payoff and of the guarantee (if any) as disclosed in the UCITS KIID, not necessarily of the underlying management techniques or structures. The KIID for structured UCITS already requires performance scenarios to provide further transparency. CHAPTER III RIGHTS OF INVESTMENT FIRMS Article 38 Access to regulated markets 1. Member States shall require that investment firms from other Member States which are authorised to execute client orders or to deal on own account have the right of membership or have access to regulated markets established in their territory by means of any of the following arrangements: (a) directly, by setting up branches in the host Member States; (b) by becoming remote members of or having remote access to the regulated market without having to be established in the home Member State of the regulated market, where the trading procedures and systems of the market in question do not require a physical presence for conclusion of transactions on the market. 2. Member States shall not impose any additional regulatory or administrative requirements, in respect of matters covered by this Directive, on investment firms exercising the right conferred by paragraph 1. EFAMA supports the provisions on fair access between venues and clearing houses, all of which should improve market resilience. Article 40 Provisions regarding central counterparty,

18 18 EFAMA comments on on MIFID clearing and settlement arrangements in respect of MTFs 1. Member States shall not prevent investment firms and market operators operating an MTF from entering into appropriate arrangements with a central counterparty or clearing house and a settlement system of another Member State with a view to providing for the clearing and/or settlement of some or all trades concluded by market participants under their systems. 2. The competent authority of investment firms and market operators operating an MTF may not oppose the use of central counterparty, clearing houses and/or settlement systems in another Member State except where this is demonstrably necessary in order to maintain the orderly functioning of that MTF and taking into account the conditions for settlement systems established in Article 39(2)34(2). In order to avoid undue duplication of control, the competent authority shall take into account the oversight and supervision oversight/supervision of the clearing and settlement system already exercised by the national central banks as overseers of clearing and settlement systems or by other supervisory authorities with a competence in such systems. EFAMA supports the provisions on fair access between venues and clearing houses, all of which should improve market resilience. New Article 40a MiFID The provision of this directive regulating the provision of services by third country firms in the Union should not affect the possibility for persons established in the Union to make use of investment services provided by a third country firm at their own initiative. When a third

19 19 EFAMA comments on on MIFID country firm provides services at the own initiative of a person established in the Union, the services should not be deemed as provided in the territory of the Union. In case a third country firm solicits clients or potential clients in the Union or promotes or advertises investment services or activities together with ancillary services in the Union, otherwise than in the course of an existing relationship requiring a continuing service provided by the firm to its client, it should not be deemed as a service provided at the own initiative of the client. The proposed Recital 74 of MiFID allows eligible counterparties to receive investment services by a third country firm only at their own initiative. It should be made clear that such passive marketing regime applies to all European clients and allows them to benefit from investment services provided by third country firms. Inclusion of Recital 74 of the proposed MiFID into an Article 40a (new) to make this provision clearly binding. CHAPTER IV Provision of Services by Third Country firms Section 1 Provision of Services with establishment of a branch Recital 72 MiFID (72) The provision of services by third country firms in the Union is subject to national regimes and requirements. These regimes are highly differentiated and the firms authorised in accordance with them do not enjoy the freedom to provide services and the right of establishment in Member States other than the one where they are established. It is appropriate to introduce a common regulatory framework at Union level. The regime should harmonize the existing fragmented framework, ensure certainty and uniform treatment of third country firms accessing the Union, ensure that and equivalence assessment has been carried out by the Commission in relation to the regulatory (72) The provision of services by third country firms in the Union is subject to national regimes and requirements. These regimes are highly differentiated and the firms authorised in accordance with them do not enjoy the freedom to provide services and the right of establishment in Member States other than the one where they are established. It is appropriate to introduce a common regulatory framework at Union level. The regime should harmonize the existing fragmented framework, ensure certainty and uniform treatment of third country firms accessing the Union, and should provide for a comparable level of protections to investors in the EU receiving services by third country firms.

20 20 EFAMA comments on on MIFID and supervisory framework of third countries and should provide for a comparable level of protections to investors in the EU receiving services by third country firms. Third country firms servicing clients in the Union shall comply with EU law therefore an equivalence assessment of their own third country regulatory and supervisory framework is not necessary. Recital 73 MiFID... The provision of services without branches should be limited to eligible counterparties. It should be subject to registration by ESMA and to supervision in the third country. Proper cooperation arrangements should be in place between ESMA and the competent authorities in the third country.... The provision of services without branches should be limited to eligible counterparties and to professional clients. It should be subject to registration by ESMA and to supervision in the third country. Proper cooperation arrangements should be in place between ESMA and the competent authorities in the third country. Where dealing with professional clients, the position under AIFMD should be followed it should be sufficient to appoint a legal representative. A physical presence in the form of a branch is not necessary. Recital 74 MiFID (74) The provision of this directive regulating the provision of services by third country firms in the Union should not affect the possibility for persons established in the Union to receive investment services by a third country firm at their own exclusive initiative. When a third country firm provides services at own exclusive initiative of a person established in the Union, the services should not be deemed as provided in the territory of the Union. In case a third country firm solicits clients or potential clients in the Union or promotes or advertises investment (74) The provision of this directive regulating the provision of services by third country firms in the Union should not affect the possibility for persons established in the Union to make use of investment services by a third country firm at their own initiative. When a third country firm provides services at own initiative of a person established in the Union, the services should not be deemed as provided in the territory of the Union. In case a third country firm solicits clients or potential clients in the Union or promotes or advertises investment services or activities

21 21 EFAMA comments on on MIFID services or activities together with ancillary services in the Union, it should not be deemed as a service provided at the own exclusive initiative of the client. together with ancillary services in the Union otherwise than in the course of an existing relationship requiring a continuing service provided by the firm to its client, it should not be deemed as a service provided at the own initiative of the client. Many investment services and activities are provided in the context of already existing relationships between the firm and the client. It would unduly limit the access of EU investors and counterparties to the services provided by third country firms if third country firms were, for example, effectively prohibited from providing information and research to their existing clients. Deletion of the word exclusive to align with AIFMD. Article 41 Para Member States shall require that a third country firm intending to provide investment services or activities together with any ancillary services in their territory through a branch acquire a prior authorisation by the competent authorities of those Member States in accordance with the following provisions: 1. Member States shall require that a third country firm intending to provide investment services or activities together with any ancillary services in their territory through a branch acquire a prior authorisation by the competent authorities of their Member State of reference in accordance with the following provisions: (a) the Commission has adopted a decision in accordance with paragraph 3; (b) the provision of services for which the third country firm requests authorisation is subject to authorisation and supervision in the third country where the firm is established and the requesting firm is properly authorised. The third country where the third country firm is established shall not be listed as Non Cooperative Country and Territory by the Financial Action Task Force on antimony laundering and terrorist financing; (c) cooperation arrangements, that include provisions regulating the exchange of (a) the third country firm intending to provide investment services or activities together with ancillary services shall comply with this Directive and Regulation (EU) No / [MiFIR]. To the extent that compliance with a provision of this Directive and Regulation (EU) No / [MiFIR] is incompatible with compliance the law to which the third country firm is subject, there shall be no obligation on the third country firm to comply with that provision of this Directive or Regulation (EU) No / [MiFIR] if it can demonstrate that: (i) it is impossible to combine such compliance with compliance with mandatory provision in the law to which the third country firm is subject;

22 22 EFAMA comments on on MIFID information for the purpose of preserving the integrity of the market and protecting investors, are in place between the competent authorities in the Member State concerned and competent supervisory authorities of the third country where the firm is established; (ii) the law to which the third country firm is subject provides for an equivalent rule having the same regulatory purpose and offering the same level of protection to the retail clients; (iii) the third country firm complies with the equivalent rule referred to in point (ii). (d) sufficient initial capital is at free disposal of the branch; (e) one or more persons responsible for the management of the branch are appointed and they comply with the requirement established under Article 9 (1); (f) the third country where the third country firm is established has signed an agreement with the Member State where the branch should be established, which fully comply with the standards laid down in Article 26 of the OECD Model Tax Convention on Income and on Capital and ensures an effective exchange of information in tax matters, including, if any, multilateral tax agreements; (g) the firm has requested membership of an investor compensation scheme authorised or recognised in accordance with Directive 97/9/EC of the European Parliament and of the Council of 3 March 1997 on Investor Compensation Schemes. (b) the provision of services for which the third country firm requests authorisation is subject to authorisation and supervision in the third country where the firm is established and the requesting firm is properly authorised. The third country where the third country firm is established shall not be listed as Non Cooperative Country and Territory by the Financial Action Task Force on antimony laundering and terrorist financing; (c) cooperation arrangements, that include provisions regulating the exchange of information for the purpose of preserving the integrity of the market and protecting investors, are in place between the competent authorities in the Member State of reference and competent supervisory authorities of the third country where the firm is established; (d) sufficient initial capital is at free disposal of the branch; (e) one or more persons responsible for the management of the branch are appointed and they comply with the requirement established under Article 9 (1); (f) the third country where the third country firm is established has signed an agreement with the Member State of reference, which fully comply with the standards laid down in Article 26 of the OECD Model Tax Convention on Income and on Capital and ensures an effective exchange of information in tax matters, including, if any,

23 23 EFAMA comments on on MIFID multilateral tax agreements; (g) the firm has requested membership of an investor compensation scheme authorised or recognised in accordance with Directive 97/9/EC of the European Parliament and of the Council of 3 March 1997 on Investor Compensation Schemes. (h) the third country firm intending to obtain authorisation shall have a legal representative established in its member State of reference. The legal representative shall be the contact point of the firm in the Union and any official correspondence between the competent authorities and the firm and between the EU clients of the relevant firm shall take place through that legal representative. The legal representative shall perform the compliance function relating to the services performed by the firm under this Directive or Regulation (EU) No / [MiFIR]. Alignment with the provisions in the AIFMD for cross border access of third country managers (Article 37 Directive 2011/61/EU). In other words, third country firms when dealing with European clients should be subject to authorisation with an authority in a member state of reference and require a legal representative. The third country firms also need to comply with the MiFID and MiFIR rule,except in very exceptional circumstances when mandatory legal constraints make it impossible for the third country firm to comply with the MiFID and MiFIR rules. Article 41 Para Member States shall require that a third country firm intending to provide investment services or activities together with any ancillary services to retail clients in those Member States' territory shall establish a branch in the Union. 2. Member States shall require that a third country firm intending to provide investment services or activities together with any ancillary services to retail clients in those Member States' territory shall establish a branch in its Member State of Reference.

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