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3rd MiFID II consultation from FCA

How conduct of business will change under MiFID II for UK firms

Today the FCA released its third of its consultation papers on how MiFID II will be implmented in the UK.

This is the installment we have been waiting for as it includes most of the detail about how the day to day operations of UK firms could be impacted by these new standards.

The paper, CP 16/29, focusses on conduct of business obligations. Key areas of interest include:

  • how inducement rules will be strengthened and the impact that will have on commission / adviser charges
  • what breakdowns of costs and charges will look like for fund managers, product providers and distributors 
  • how suitability and appropriateness will be affected by MiFID II
  • the extension of telephone call recording requirements to financial advisers

We'll be looking at all the proposals in depth and submitting a response to the FCA to highlight any areas where their proposed implementation of MiFID II might caused difficulty for UK firms.

If you think the changes impact you, we'd recommend you read the paper and consider what changes you mimght need to make, and whether to flag any difficulties to the FCA.

The deadline for responding is 4 January 2017. That sounds far away but, at 586 pages, there is quite a lot to think about in the consultation paper!

Previous consultations

Although we think this is the most significant FCA consultation on MiFID II, to get the full picture you will want to be aware of the others also.  

The third paper was meant to be the final instalment but the FCA but a fourth paper has been announced. We're expecting this at the end of the year.

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