The MiFID 2 Project Leaders Group set up at end-2015 continued its work between May and July 2016, holding three thematic meetings on product governance and cost & expense reporting. It is currently preparing an implementation guide on product governance.
Level 3 measures
AMAFI pursued discussions with the AMF as part of ESMA’s work on Level 3 guidance, even though Level 2 measures are still being published.
- On investor protection questions, where ESMA’s work is furthest advanced, AMAFI stressed issues raised by the Compliance Committee and the MiFID 2 Project Leaders Group. Because of their implications, product governance aspects were a central focus. Other topics discussed included placement and underwriting obligations, suitability tests, recording of conversations and communications, best execution, as well as costs and expenses.
- On market structure aspects, which are to be covered by a Q&A released by ESMA this autumn, AMAFI flagged a number of issues, including the treatment of OTC derivatives. The AMF met with representatives of the Market Structure Committee and the MiFID 2 Project Leaders Group in late August to discuss the work underway at European level.