This new requirement is posing some questions about how it can best be implemented. We think that firms should wait
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There are some apparent anomalies in the rules. We have obtained 'clarification' from the FCA.
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How will changes to compliance governance affect your company?
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The FCA has clarified some aspects of how the recording rules will apply to firms that are not Article 3
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New MiFID II ‘Confirmation of Continued Suitability’ Process
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Suitability remains much the same as pre-MiFID II but there are some changes that firms need to be aware of.
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Although the new rules do not take effect until May 2018, it makes sense to consider them alongside MiFID disclosure
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Firms need to understand the implications of the MiFID II definition of independent advice.
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MiFID II brings a new definition of independence - firms need to consider if they can meet the requirements.
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New requirement to disclose costs at least annually
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