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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 |
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| Financial & Insurance Risk Actuary | ||
| Scotland / hybrid 2 dpw office-based - Negotiable | ||
| Pensions (Scheme) Regulation Director... | ||
| London or Birmingham with flexible hybrid working - Negotiable | ||
| Cross-Asset Structurer - International | ||
| Zurich - Negotiable | ||
| BPA Transition Manager | ||
| South East - Negotiable | ||
| Calling all technical pensions specia... | ||
| North West with a range of hybrid working options - Negotiable | ||
| Take the lead on London Market pricing | ||
| London – 3 days per week in the office - Negotiable | ||
| Head of Capital | ||
| London - Negotiable | ||
| Divisional Reinsurance Actuary | ||
| London - £170,000 Per Annum | ||
| Associate - BPA Origination & Execution | ||
| London / hybrid 3 dpw office-based - Negotiable | ||
| Data Manager (Pensions) | ||
| Manchester or London / hybrid 2-3 dpw office-based - Negotiable | ||
| Defined Benefits Pensions Manager - C... | ||
| Manchester or London / hybrid 2-3 dpw office-based - Negotiable | ||
| DB Pensions Senior Manager | ||
| Manchester or London / hybrid 2-3 dpw office-based - Negotiable | ||
| Reserving & Capital Actuary | ||
| London – 2 days per week in the office - Negotiable | ||
| The Strategist - Market Pricing | ||
| South East / remote with 1 day per month in the office - Negotiable | ||
| M&A Actuarial Analyst - Non-life | ||
| London / hybrid with 2 days p/w office-based - Negotiable | ||
| Move to Life | ||
| South East / hybrid 3dpw office-based - Negotiable | ||
| Actuarial Risk and Capital Consultant | ||
| South East / hybrid 3dpw office-based - Negotiable | ||
| Actuarial Systems Consultant | ||
| South East / hybrid 3dpw office-based - Negotiable | ||
| Actuarial Systems Manager | ||
| South East / hybrid 3dpw office-based - Negotiable | ||
| Head of Pricing and Analytics | ||
| London/Leeds/Hybrid - £150,000 Per Annum | ||
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