![]() |
In their recent response to the European Securities and Markets Authority’s (ESMA) Call for Evidence on Inducements and Costs and Charges Disclosure Requirements under Markets in Financial Instruments Directive (MiFID) II, PIMFA has outlined their concerns about the complexity of these disclosure requirements and the burdens they place on firms seeking to comply with those requirements. Although ESMA suggests that certain difficulties identified with the current regime can best be addressed through further, more detailed rules and mandated presentation formats. |
PIMFA has responded saying that MiFID II should not provide any more detailed rules governing the timing, format and presentation of these disclosures at this current time as well as loading further significant costs on firms. They argue, this would only serve to further confuse consumers, many of whom are less than clear about what the new MIFID II disclosures mean. Instead, if amendments to the MiFID II costs and charges regime are required, they should be subject to a review process that requires detailed consultation, cost-benefit analysis and consumer testing, while also taking into consideration the industry, consumer and supervisory experience of the operation of the current regime to date. Sarah McGuffick, Lead Regulatory Policy Adviser at PIMFA said: “We have made it clear that, if there was to be any hope of MiFID II being applied consistently across the industry, the regulators would need to provide unambiguous and detailed provisions on which firms could base both systems specifications/development. This, in turn, could result in the necessary changes to in-house processes and procedures. The fact that this did not happen has resulted not only in firms incurring huge costs in interpreting and applying regulation but also in their diverting resources away from their most important function, namely the day-to-day servicing of their clients’ needs and wishes.”
Read the full consultation response |
|
|
|
| Lead Capital Actuary | ||
| London - £150,000 Per Annum | ||
| Take the lead on capital oversight | ||
| London / hybrid 2 days p/w office-based - Negotiable | ||
| Be at the forefront of creative GI co... | ||
| London/hybrid 2-3dpw office-based - Negotiable | ||
| Remote Market and Credit Risk Calibra... | ||
| Remote - Negotiable | ||
| Contact us about a Capital Contract i... | ||
| London / hybrid 2 days p/w office-based - Negotiable | ||
| Head of Insurance Risk | ||
| London - £160,000 Per Annum | ||
| Director - Pensions Risk Transfer (PRT) | ||
| London, Midlands, North West - hybrid working 2dpw in the office - Negotiable | ||
| Dip a toe into public sector work wit... | ||
| Flex / hybrid 2 days p/w office-based - Negotiable | ||
| P&C Consultant | ||
| London / hybrid 3dpw office-based - Negotiable | ||
| Take the lead client-facing projects ... | ||
| Various locations - Negotiable | ||
| Choose Life! Choose a major global co... | ||
| Various locations - Negotiable | ||
| Actuarial skillset? Apply now for Snr... | ||
| South East / hybrid with travel requirements - Negotiable | ||
| Financial Risk Leader - ALM Oversight | ||
| Flex / hybrid - Negotiable | ||
| Be the very model of a modern Capital... | ||
| London - Negotiable | ||
| Pensions Actuary seeking a high-impac... | ||
| London or Scotland / hybrid 3dpw office-based - Negotiable | ||
| Great opportunity for Pensions Actuar... | ||
| London or Scotland / hybrid 3dpw office-based - Negotiable | ||
| Responsible Investing Manager - Clima... | ||
| London/Hybrid - Negotiable | ||
| Quant Strategist | ||
| London/Hybrid - Negotiable | ||
| Play a vital role in shaping a new He... | ||
| London or Scotland / hybrid 50/50 - Negotiable | ||
| Support the Longevity team of a globa... | ||
| London / hybrid 2 days p/w office-based - Negotiable | ||
Be the first to contribute to our definitive actuarial reference forum. Built by actuaries for actuaries.