Investment - Articles - Zurich comment on MiFID

 "We welcome the FCA's MiFID consultation, which has taken a common sense approach to many of the issues, and holds out the prospect of continued engagement with the industry in developing the details. 

 "For advice firms, one of the big practical considerations is the requirement to record telephone conversations. It is good that the FCA has said it is willing to consider alternative approaches to taping. We would encourage the FCA to engage with advice firms on this issue, as ultimately it is consumers that will have to pay for any overly burdensome regulation.

 "The FCA has promised to take an 'appropriate and proportionate' approach to proposals on product governance, and has said that it expects 'the introduction of the new provisions to be an evolution of existing standards rather than requiring significant change.' This is a very encouraging statement, as the product governance requirements could have led to a prescriptive and bureaucratic approach that would have delivered little in the way of consumer protection.

 "On the issue of the boundary between complex and non-complex products, the FCA has allowed, as much as possible, firms to make a judgement on whether the nature of the investment they are selling means that an appropriateness test should be used. This is a sensible approach that allows firms to deliver a strong customer experience."