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Mikkel Bates


Recent Posts

Greater clarity on assessing a PRIIP’s Recommended Holding Period

By Mikkel Bates

The Joint Committee of the three European regulators responsible for PRIIPs has just updated its Q&As and includes a detailed answer on how to arrive at the Recommended Holding Period (RHP) of a PRIIP. 

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Good and bad in MiFID II cost disclosure, says FCA review

By Mikkel Bates

The FCA has recently published the findings from its review of MiFID II costs and charges disclosure.  The review covered 50 firms and found different interpretations of the rules.

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FCA issues Feedback Statement on its PRIIPs Call for Input

By Mikkel Bates

Despite a lack of ability to do much at a local level about PRIIPs, the FCA issued a Call for Input (CfI) last year to ask for industry views on issues such as the scope of the PRIIPs Regulation and the calculation and presentation of risks, returns and costs on a KID.  It deserves a muted round of applause for acknowledging the industry’s concerns and for publishing its Feedback Statement, FS19/1, responding to the huge number of responses it received to the CfI.

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ESMA consulting on sustainability risks in product governance and suitability

By Mikkel Bates

While much attention since MiFID II came into force a year ago has been on cost disclosure, the European regulator ESMA has published two consultation papers (CPs) on integrating sustainability risks and factors in MiFID II, tightening up on suitability of advice, and in UCITS and AIFMD, incorporating them in product governance.

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FCA’s Temporary Permissions Regime opens for business

By Mikkel Bates

Following its CP18/29 at the end of last year, the FCA has now opened its doors to firms and funds from Europe to register their intention to apply for full UK authorisation following Brexit.

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ESMA Securities and Markets Stakeholder Group (SMSG) responds to PRIIPs consultation paper

By Mikkel Bates Regulations

ESMA’s SMSG – its own panel of advisers, made up of industry participants, consumers and academics – has published its advice to ESMA on the proposals in the PRIIPs Consultation Paper, JC 2018 60, and it doesn’t pull any punches.

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ECON calls for two-year extension to UCITS exemption from PRIIPs KIDs

By Mikkel Bates Regulations

In the middle of the European Supervisory Authorities’ (ESAs) consultation on PRIIPs KIDs, there was cross-party agreement in the European Parliament’s Economic and Monetary Affairs Committee (ECON) that the target date for UCITS to publish PRIIPs KIDs should be extended by two years, from December 2019 to 2021.

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PRIIPs KIDs annual review

By Mikkel Bates Regulations

One of the few positive things that can be said about PRIIPs KIDs is that, unlike UCITS KIIDs, they don’t all need to be updated during the same short window at the start of every year.  So PRIIPs providers can stagger their workload throughout the year, carrying out their annual reviews after their funds’ accounting dates, possibly.

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Confusion over the demise of UCITS KIIDs and the future of PRIIPs KIDs

By Mikkel Bates Regulations

The European Supervisory Authorities (the ESAs, made up of ESMA, EBA and EIOPA), have published a series of letters between them and the European Commission (EC), over the proposed ending of the exemption for UCITS KIIDs at the end of 2019.

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AIC calls for KIDs to be suspended

By Mikkel Bates Regulations

On 11 September, the Association of Investment Companies (AIC) published a report detailing the extent of misleading output, particularly in the risk and reward sections, of PRIIPs KIDs.

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