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MIDIF 2 Refit – European Commission Consultation – AFPDB Reply

On the occasion of the European Commission Consultation on the review of MiFID II and MiFIR, the French association of retail structured product manufacturers, would like to share its views with the Commission on its experience with these current regulations and on the possible improvements that could be brought to the existing regulatory framework.

The AFPDB’s contribution to the consultation focuses on investor protection topics which get specific importance to the structured products industry:

  • General questions (questions 1 to 6)
  • Product governance and investor protection (questions 31 to 34),
  • Priority changes to be made, paper phase-out (questions 35 to 36)
  • Creation of a pan-European product information database managed by ESMA (questions 37
  • to 39)
  • Creation of a new category of semi-professional clients (questions 40 to 45),
  • Modification of the product governance regime (questions 46 to 48),
  • Abolition or recalibration of the inducement regime (questions 49 and 50),
  • Delayed delivery of information (question 53)
  • Opportunity of record-keeping tools in order to avoid mis-selling products (question 54)
  • Opportunity of adapting the distribution regulations in order to suit digital and online offers (question 90)
Last update : 19 May 2020

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