EFAMA welcomes ESMA’s Consultation Paper on product governance requirements and specifically on the target market assessment and supports that the details of these requirements are laid out in the form of guidelines rather than Q&A. We agree with ESMA that drafting target market guidelines is an important aspect “for ensuring the common, uniform and consistent application” of the MIFID II product governance requirements, in particular since these rules have the potential to significantly alter the European distribution landscape. We are broadly supportive of ESMA’s proposals and consider them to be well–balanced in many aspects. In particular, given the degree of intermediation in the funds market, and given that very many UCITS and retail AIF are designed with a particular investment strategy that should be available to firsttime investors or would sit well within very many investors’ portfolios, we support ESMA stressing that manufacturers can define a target market only on an abstract basis.
EFAMA’s comments on ESMA’s CP on draft guidelines on MiFID II product governance requirements
19 December 2016 | Policy position