mifid ii emt and costs & charges seminar - tisa - tax ... · mifid ii emt and costs &...

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MiFID II EMT and Costs & Charges Seminar

AXA IM, 7 Newgate Street, London EC1A 7NX

@uktisa@uktisa

Jeffrey MushensTechnical Policy Director, TISA - Chair

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Agenda

• Opening remarks by Jeffrey Mushens, Technical Policy Director, TISA – Chair

• Mark Sherwin, Senior Adviser, Financial Reporting, The IA ‘

• Jeffrey Mushens ‘Costs & Charges’

• Costs & Charges Panel Session: Paul Fraser, Senior Manager, Deloitte LLP; Charlotte Henry, Partner, Norton Rose Fulbright, Mark Sherwin, Senior Adviser, Financial Reporting, The Investment Association

• Coffee Break

• Steve Bennett, Director, Good Conduct Consulting ‘The Target Market Journey’

• Ghislain Perisse, Head of Insurance Business and Services Development, AXA IM ‘EMT’

• EMT Panel Session: Steve Bennett; Ghislain Perisse; John Dowdall, Managing Director, Silverfinch

• Closing remarks by Jeffrey Mushens - Chair

@uktisa@uktisa

Mark SherwinSenior Adviser, Financial Reporting, The IA

Costs & Charges: Product costs

Costs and Charges: Product costs

Mark Sherwin

14 September 2017 Costs and Charges: Product costs 5

14 September 2017

AGENDA

1. IA cost disclosure work

2. Regulatory context

3. Fund distribution

4. MiFID II cost disclosure

5. Ex ante product costs

‒ Transaction costs

‒ Research payments

‒ Funds of funds

6. Ex post product costs


IA COST DISCLOSURE WORK

• Costs and Charges Working Group

• Analyse methodologies in PRIIPs RTS and CP16/30, their application to MIFID disclosures, and agree common approaches to solving issues

• Disclosure Code

• Develop a coherent product neutral data set to support data provision

• Template adopted by LGPS Advisory Board

• IA consultation on template’s application to the wider pensions market

• Overseen by Independent Advisory Board

• Next steps

• FCA IDWG to take forward, aiming to agree by end of 2017 a standardised disclosure template building on work already done

by IA, LGPS and others

• https://www.fca.org.uk/firms/institutional-disclosure-working-group


https://www.fca.org.uk/firms/institutional-disclosure-working-group


DWP/FCA

Workplace DC pensions:Transparency of Charges and Costs

PRIIP KID

Retail products

MiFID II

Broad coverage across portfolio mgt.

and distribution

UCITS KIID

Outside PRIIP KID until

31 Dec 2019

In force ??? 1 Jan 2018 3 Jan 2018 In force

Distribution costs

Duty to obtain and report total charges.Charges capped in default arrangement.Member-borne adviser commission banned.

Out of Scope Out of Scope Aggregation of distribution, product and transaction costs. Breakdown on request.

Out of Scope

Product charges

Duty to obtain and report total charges.Charges capped in default arrangement.

Managers must report their service charges to client (trustees and pension provider).

Aggregation and summary indicators of one-off, ongoing, contingent and transaction costs.

Aggregation of one-off, ongoing, contingent and transaction costs.Breakdown on request.

Summary indicators of one-off, ongoing and contingent charges.

Transaction costs (explicit and implicit)

Duty to obtain and report (IGCs and trustees).

CP 16/30 proposal(October 2016).

Policy Statement (September 2017).

Summary indicator and included in aggregation.

Included in aggregation. Narrative if significant.

REGULATORY CONTEXT

FUND DISTRIBUTION

FUNDS

DC Workplace Pensions

LGPS

Direct to client

Insurance wrappers

(PRIIPs)

DPM mandates (MiFID II)

Product distributors (MiFID II)

Costs and Charges: Product costs 914 September 2017

POOLED FUND COST COLLECTION TEMPLATE For use with investments in pooled funds

All figures in % of average NAV pa unless specified

Fund Manager

Fund name

Share class name

Date of report

Investment return (% pa) 1 year 3 years 5 years 10 years Since formation

Net return

Investment activity (GBP unless specified) Total Equity Bonds Property Pooled funds Other (specify)

Opening assets

Closing assets

Purchases 0

Sales 0

Turnover (% pa) %

Management fees Total (GBP)

Invoiced fees (less any rebates)

VAT (if applicable)

Total 0

Client-specific data Client (GBP) To be completed by the investing client in order to calculate client-specific amounts

Average value of client holding

Ongoing charges Client (GBP) Total

Managers fees

Other fees

Indirect fees

Total ongoing charges figure 0 0.00%

Performance fees Client (GBP) Total

Performance fees 0

Transaction costs Client (GBP) Total Equity Bonds Property Pooled funds Derivatives Foreign exchange Other (specify)

Transaction taxes 0.00%

Broker commission 0.00%

Implicit costs 0.00%

Entry/exit charges 0.00%

Indirect transaction costs 0.00%

Other transaction costs (specify) 0.00%

Anti-dilution offset -0.01%

Total transaction costs 0 -0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Stock lending (if applicable) Total

Value of stock on loan %

Gross income

Less: income shared (name recipients) %

Income retained by pooled fund 0 %

LGPS/IA template

UCITS: UCITS KIID

NURS: UCITS-like KIID

Other AIFs: PRIIP KID

FCA IDWG building on IA, LGPS, other templates

Policy statement to CP 16/30 in Q3

Data transfer to insurers to feed PRIIP KID

“EPT”

Data transfer todistributors to feedMiFID II ex anteand ex post costdisclosures

“EMT”

Aggregate productand service costs

Disclosure providedalongside KIID/KID

MIFID II COST DISCLOSURE

• Product cost calculation methodology

• CDR Article 50

• ESMA Q&As: apply PRIIPs RTS annex VI methodologies, as appropriate

• IA guidance

• Product cost delivery

• EMT

• Generic product specific information, not distributor specific

• Product cost presentation

• CDR Article 50, ESMA Q&As

• FCA IDWG template

• TISA guidance


EX ANTE PRODUCT COSTS

• CDR 50(8):

• Use actually incurred costs if available, otherwise make reasonable estimations

• One-off costs:

• Maximum amount actually paid to product supplier

• Adjusted by distributor according to commercial arrangements

• Ongoing costs:

• Ongoing charges as per KIID

• Transaction costs:

• As provided by fund manager

• Incidental costs:

• Performance fees for the last year as per KIID or 5 year average?


TRANSACTION COSTS

• Explicit costs extracted from accounting records

• Implicit costs calculated according to an appropriate methodology

• PRIIPs arrival price methodology

• Difference between arrival price and trade price

• Arrival time: when order transmitted to broker or when trade is executed

• Arrival price: mid-market price or mid of two way quotes or evaluated prices

• PRIIPs “new funds” methodology

• Bonds: Weighted average spread of a reference index

• Equities, ETDs: comparable information or spread as per bonds

• OTC derivatives: observed cost based on spread

• Practical alternatives

• Wider use of comparable information

• Weighted average spread of portfolio

• Outputs from best execution analysis


RESEARCH PAYMENTS

• Under MiFID II research can be paid for in two ways:

• From the managers own resources (P&L)

• From a client-funded research payment account (RPA)

• An RPA and a research budget is established for each strategy

• The RPA is funded by clients/funds in one of two ways:

• Separate research charge

• Collected alongside transaction commission

• Research charge cannot be linked to the volume/value of transactions

• Research charges cannot exceed the specified budget

• Research charges are not transaction costs. Therefore they must be captured in the OCF

• Prior to 2018 there were no research charges, only bundled commissions


FUNDS OF FUNDS

• UCITS produce a synthetic ongoing charges figure

• OCF of underlying funds at end of period

• Offset any rebates or retrocessions

• Actual entry/exit costs paid during the period

• Threshold holding size

• Additional requirements under MiFID II

• Create synthetic transaction costs figure on same basis as OCF

• Include OCF and transaction costs of underlying investment trusts

• No threshold holding size


EX POST PRODUCT COSTS

• CDR 50(9):

• Use costs incurred, presented on personalised basis

• Product cost delivery

• EMT

• Generic product specific information, not client specific

• FCA policy statement to CP16/30:

• Will define ex post methodologies for transaction costs in funds used by UK pension schemes

• CP16/30 proposals aligned with PRIIPs arrival price methodology, no new consultation since

• Expected in September 2017

• FCA IDWG template:

• Will define ex post data set for institutional disclosures

• Building on work already done by IA, LGPS and others

• Expected in 2017


16

Mark [email protected]

mailto:[email protected]

@uktisa@uktisa

Jeffrey MushensTechnical Policy Director, TISA

Costs & Charges

@uktisa

Introduction

• What's in the guide?

• Timings

• Ex ante for funds

• Ex ante for discretionary/advisory

• Ex post for funds

• Ex post for discretionary/advisory

• Cumulative effect of charges

• EMT

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Timings and dates

• 3rd January 2018 - D-Day for ex ante

• When are annual reports for retail required?

• What about discretionary/institutional?

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Table 1 of Annex II of MiFID Delegated Regulation

Cost items to be disclosed

Description Examples

One-off charges related to the provision of an investment service

All costs and charges paid to the investment firm at the beginning or at the end of the provided investment service(s).

Deposit fees, termination fees Switching costs (costs that can be incurred by investors by switching from one investment firm to another investment firm).

On-going charges related to the provision of an investment service

All on-going costs and charges paid to investment firms for their services provided to the client.

Management fees, advisory fees, Custodian fees.

All costs related to transactions initiated in the course of the provision of an investment service

All costs and charges that are related to transactions performed by the investment firm or other parties.

Broker commissions (costs that are charged by investment firms for the execution of orders), entry- and exit charges paid to the fund manager, platform fees, mark ups (embedded in the transaction price), stamp duty, transactions tax Foreign exchange costs.

Any charges that are related to ancillary services

Any costs and charges that are related to ancillary services that are not included in the costs mentioned above.

Research costs. Custody costs.

Incidental costs Performance fees

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Table 2 of Annex II of MiFID Delegated Regulation

Cost items to be disclosed

Description Examples

One-off charges All costs and charges (included in the price or in addition to the price of the financial instrument) paid to product suppliers at the beginning or at the end of the investment in the financial instrument.

Front-loaded management feeStructuring fee (fees charged by manufacturers of structured investment products for structuring the products. They may cover a broader range of services provided by the manufacturer )Distribution fee.

On-going charges All on-going costs and charges related to the management of the financial product that are deducted from the value of the financial instrument during the investment in the financial instrument.

Management fees, service costs, swap fees, Securities lending costs and taxes, financing costs.

All costs related to transactions

All costs and charges that incurred as a result of the acquisition and disposal of investments.

Broker commissions, entry- and exit charges paid by the fund, mark ups embedded in the transaction price, stamp duty, transactions taxForeign exchange costs.

Incidental costs Performance fees

@uktisa

• Ex ante in practice – an example – Handout 1

• Ex post – Handout 2

• Ex post – an example – Handout 3

• Itemized breakdown of costs – Handout 4

• Ex Post Fund – Fund of Funds Template – Handout 5

Ex ante in practice – an example – Handout 1

Ex post – Handout 2

Ex post – an example – Handout 3

Itemised breakdown of costs – Handout 4

Ex Post Fund – Fund of Funds Template – Handout 5

@uktisa

Cumulative effect of charges

Cumulative effect of cost and charges on return of investment

Percentage (%) Amount (Ccy)

Return before the deduction of cost and charges (gross) 7.56% £756

Return after the deduction of cost & charges (net) 5.28% £528

Cumulative effect of cost & charges (Difference) 2.28% £228

@uktisa

Alternatively Investment Firms could use a graph to illustrate the effect feeshave had on the return throughout the last year, such as the below.

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EMT

• Final version published 3 August 2017

• Produced by EWG and endorsed by EFAMA. TISA has endorsed

• Chapter in the Approach to implementation

@uktisa@uktisa

Panel Session: Costs & ChargesPaul Fraser, Deloitte LLP

Charlotte Henry, Partner, Norton Rose FulbrightMark Sherwin, Senior Adviser, Financial Reporting,

The Investment Association

@uktisa@uktisa

Steve BennettDirector, Good Conduct Consulting

The Target Market Journey

Good Conduct Consulting

Target Market & EMT – the Journey So Far…and to come!Steve Bennett14 September 2017

29Good Conduct Consulting

Before MiFID – Spring ‘15

Property of Good Conduct Consulting, not to be used w ithout permission


TISA/IA Target Market Sub-Group



The UK Industry Target Market Model – c. Jan 2016

Target Market FrameworkClient Type

(Sales Data/MI)

a. Retailb. Professional

c. Eligible Counterparty

Knowledge & Experience

a. Basic b. Informed

c. Expert

d. Non-retail

Ability to bear losses

a. The investor seeking to preserve capital or can bear losses to a level specified by the product structureb. The investor can bear losses

c. The investor can bear losses beyond the investment amount

Client objectives

Return profilea. Preservation

b. Growth

c. Incomed. Other

Time Horizon:a. Short (e.g. <3 years)

b. Medium (e.g. > 3 years)

c. Long (e.g. > 5 years)

Client needs

Usagea. Solution

b. Core of a Portfolio

c. Component of a Portfolio

Access (withdrawals)a. Ready access – in foreseeable market

conditions

b. Ready access – normal market conditionsc. Ready access with restrictions

d. Access uncertain

Distribution

Distribution

(Sales Data/MI)

MiFID Defined Distribution Categories:a. Execution Only (retail)

b. Advised (retail)

c. Portfolio management (retail) d. Non-Retail

e. Not Known/Non-EU

Distributor Type:a. Independent

b. Non-Independent

Appropriateness test:

a. Yes

b. No



The European Tour – Spring ‘16



European Fund Industry Negotiations!



European Fund Industry Harmony – July ‘16



The Birth of FIDWG

…but What About the Distributors?

The

Manufacturers

are jawing…..

…and so

FIDWG was

born!



Target Market Framework

Client Type

• Retail (Y/N/Null)

• Professional (Y/N/Null)

• Eligible Counterparty (Y/N/Null)

Knowledge &

Experience

• Investor with basic knowledge (Y/N/Null)

• Informed investor (Y/N/Null)

• Experienced (Y/N/Null)

Ability to bear

losses

• The investor seeking to preserve capital or can bear losses limited to a level specified by the product (Y/N/Null)

• The investor can bear losses, i.e. no capital guarantee (Y/N/Null)

• The investor can bear losses beyond the investment amount (Y/N/Null)

Client objectives

Return profile:

• Preservation (Y/N/Null)

• Growth (Y/N/Null)

• Income (Y/N/Null)

• Hedging (Y/N/Null)

• Other (Y/Null)

Time Horizon:

• Recommended Holding Period

• Value measure: day/month/year;

• Value amount: integer)

• Maturing product

• Hold to maturity (Y/Null)

• Maturity Date

• Indicative Holding Period, five fields:

• Short (Y/N/Null)

• Medium (Y/N/Null)

• Long (Y/N/Null)

Client needs

Usage:

• Standalone investment (Y/N/Null)

• Core or Component of a Portfolio (Y/N/Null)

• Specific investment need (Y/Null)

• Other usage (Y/Null)

Risk

• SRRI (for those products which product a KIID, e.g. UCITS)

• SRI (for PRIIPS)

• LMH – i.e. Low, Medium or High (for products without SRRI/SRI)

Channel

• RTO (Y/N/Null)

• Investment Advice (Y/N/Null)

• Portfolio Management (Y/N/Null)

Key Y = Directly in the target market N = Clearly outside of the target market (Negative Target Market)

Null = Manufacturer wasn’t designing the product for this use but accepts it may be compatible

Target Market – Funds’ Industry Model c. January ‘17



BUT…what about Communication – and the rest of the Industry?

And so EMT is born!Property of Good Conduct Consulting, not to be used w ithout permission


The EMT & the Attempted Coup!



Target Market Framework

Client Type • Retail (Y/N/Neutral) • Professional (Y/N/Neutral/P/E/B) • Eligible Counterparty (Y/N/Neutral)

Knowledge &

Experience

• Investor with basic knowledge (Y/N/Neutral)

• Informed investor (Y/N/Neutral)

• Informed investor (Y/N/Neutral)

• Advanced Investor (Y/N/Neutral)• Expert Investor (Germany Only) Optional (Y/Neutral)

Ability to bear

losses

• 1. The investor can bear no loss of capital; capital 100% guaranteed (Y/N/Neutral)

• 2. The investor seeking to preserve capital or can bear losses limited to a level specified by the product (Y/N/Neutral)

• 2a. Optional percentage capital guaranteed

• 3. The investor can bear losses, i.e. no capital guarantee (Y/N/Neutral)

• 4. The investor can bear losses beyond the investment amount (Y/N/Neutral)

Client objectives &

needs

Return profile:

• Preservation (Y/N/Neutral)

• Growth (Y/N/Neutral)

• Income (Y/N/Neutral)

• Hedging (Y/N/Neutral)

• Option or Leveraged Return Profile (Y/N/Neutral)

• Other (Y/Neutral)

• Specific Pension Scheme Germany (Y, Neutral)

Specific investment need (G - Green, E - Ethical, I - Islamic, S - ESG, O - Other)

Time Horizon:

• RHP or IHP (RHP – Years; IHP – V- Very Short (<1 year), S- Short (<3 years),

M – Medium (<5 years), L – Long (>5 years), Neutral

• Maturing product:

• Maturity Date

• May be terminated early (Y/N/Neutral)

Risk

• SRRI (for products using the UCITS risk indicator)

• SRI (for PRIIPS)

• LMH – i.e. Low, Medium or High (for products without SRRI/SRI)

• Risk Measure non-UCITS/Non-PRIIPS Spain (1-6)

• Not for investors with lowest risk tolerance (Germany) (Y/Neutral)

Channel

• Execution Only (R – Retail, P – Professional, B – Both, N – Neither)

• Non-Advised with Appropriateness Test (R – Retail, P –

Professional, B – Both)

• Investment Advice (R – Retail, P – Professional, B – Both)

• Portfolio Management (R – Retail, P – Professional, B – Both)

Key:

Y

N

Neutral

Positive target market - i.e. the product is intended for this aspect of the target market framework

Negative target market – i.e. the product is not intended for this aspect of the target market framework

Neither Positive or Negative – i.e. Manufacturer wasn’t designing the product for this use but accepts it may be compatible

Target Market – the Final(?) Model


So, It’s done…or is it?


Target Market – Informing Product Governance Decision Making

Client Type

Knowledge & Experience

Ability to bear losses

Client ObjectivesReturn profile

Time horizon

Client needs:Usage

Specific

Risk

Distribution Channel

Distribution Channel Product Provider

Marketing Strategy

Product Offering (esp. RTO)

Marketing Strategy

Drives ex Ante Product

Governance Decisions

Investor

Investment Recommendations

(Advisory)

Investment Decisions

(Portfolio Mgt)

Product descriptions

Investment Decisions

(Advice & RTO)

Informs specific investment

decisions; must be seen in the

context of the client’s portfolio

!!! Consistency of application to products and product governance decisions across the industry is essential …. inconsistent approaches may lead to regulatory and/or

commercial arbitrage, as well as confusion and misapplication in practice !!!



Knowledge and Experience the FIDWG ex ante Decision-Tree

Product Description

Knowledge &

Experience/

Client Type

Distribution Channel

RestrictionsMarketing restrictions

Distributor training

requirements

Investors with no financial industry experience or

knowledge outside that provided by the regulated and

authorised offering documentation and/or basic

information provided at the point of sale are able to

make an informed investment decision regarding the

product

Yes

→

Retail: Investor

with Basic

Knowledge

None None

N/A - if available execution

only, then distributor

training is irrelevant as they

do not provide a

recommendation

No ↓Investors with either experience in investing in

products with these characteristics or who have

knowledge and understanding of the specific risks

highlighted in the regulated and authorised offering

documentation and/or basic information provided at

the point of sale, are able to make an informed

investment decision regarding the product

Yes

→

Retail: Informed

investor

None - still available

execution only, but not "in

the shop window"

Target at informed investors -

e.g. mainstream investor

press etc

N/A - if available execution

only, then distributor

training is irrelevant as they

do not provide a

recommendation

No ↓

An informed investment decision can be made by:

- Investors with a good knowledge and/or experience

of investing in financial products, or

- Basic investors in receipt of investment advice, or

gaining access through a discretionary portfolio service

Yes

→

Retail: Advanced

investor

Consider restricting to

exclude Execution only

where possible

As for informed investors

above

Potentially - Evaluate

whether distributors would

benefit from training on the

features of the product

No ↓

Product not suited to Retail Investors.Non-Retail

investors only

Consider restricting to

professional investors only

where possible;

Consider whether individual

distributors are appropriate

Restrict marketing to

professional investors

N/A - not providing product

for distribution



Distributor/Target Market Oversight


The Final Guidelines – Summer ‘17

Paragraph 55!



FIDWG Distributor Oversight Proposal

Risk Based Distributor due

diligence

Distributor universe

Non-Complex Products

Distributor universe

Complex Products

Follow-

up

Risk-based distributor due diligence: supplementing existing distributor oversight undertaken by product providers;

applies to all distributors

Risk based aggregated holdings/transaction reporting & appropriateness test result: for complex instruments

only, although product providers may choose to seek such reporting more broadly

Follow-up: on material exceptions, which may include a request for further information, such as on complaints, or

appropriateness assessment results for complex products

In addition to existing distributor oversight

activities



• Easy bit is done – we’ve defined the template!

• Industry standardisation is the key:

– Coherent application across investments:

• Different types of fund; and

• Fund vs. other investments (e.g. structured products)

• Geographically consistent

– Aligned product governance decisions – based on target market:

• By product providers; and

• By Distributors..

• Across instrument types and between countries

– Consistent target market oversight approach – across product types

Next Steps & Challenges


FIDWG is aiming to address all of these challenges – whilst meeting the

investor protection aims of the regulation … in a proportionate manner


Steve Bennett left Aberdeen Asset Management in February 2017 and set up as an independent consultant. Prior to its acquisition by Aberdeen, Steve was Head of Risk

for Scottish Widows Investment Partnership, responsible for the risk framework and controls and compliance oversight for the business. Earlier in his career, Steve also

held various senior compliance, risk and finance positions at firms including Aviva Investors, Citibank and Barclays Global Investors.

At Aberdeen, Steve was responsible for developing the firm’s response to the FCA’s conduct agenda in the UK, developing innovative approaches to quantifying “value for

money”, product oversight and integrating evidence of good conduct into business reporting and into the risk management framework of the firm. In 2015, Steve devised

Aberdeen’s approach to target market, which has subsequently formed the basis for the target market developments in the UK under TISA and the IA, as well as at a

European level under EFAMA.

In 2016, Steve launched a cross-industry working Group (FIDWG), uniquely drawing together major internationally active product providers, intermediaries and distributors

to ensure that the target market framework worked for all parties in the distribution chain. The working group achieved consensus on the target market approach, with

some minor but important amendments. Steve took a delegation from the Working Group to present their position to ESMA in November 2016, and wrote a cross-industry

response to ESMA’s product governance consultation paper, signed by the participating firms, which is available on the ESMA website. The working group is continues to

strive for industry consensus, but has now reformed into a closed consulting group with fee-paying members.

Steve now offers consulting and speaking services to the industry in the areas of risk management, good conduct and MiFID II product governance.

Contact Details:

Email: [email protected]

Telephone: +447714757518

About Good Conduct Consulting

mailto:[email protected]

@uktisa@uktisa

Ghislain PerisseHead of Insurance Business and Services Development,

AXA IMEMT

THIS DOCUMENT IS CLASSIFIED

RESTRICTED

Its distribution is limited solely to the AXA IM Staff members and service providers appearing in the circulation perimeter shown.

MIFID Industry Update: the EMT

Ghislain Perisse,

Head of business development, AXA IM

EWG founder

14th September 2017

European Working Group

EWG

European Working Group

RESTRICTEDProperty of AXA IM. Reproduction prohibited without the prior consent of AXA

IM

The EWG is an informal club, set up in 2014….It gathers asset managers, insurers, bankers, distributors from all Europe

The European Working GroupThe member associations:

• European sponsors: EFAMA, Insurance Europe, European Savings and Retail Banks Group,WSBI-ESBG, EACB, EBF

• Local associations: BVI, GDV, DSGV, BDB (Allemagne), Assogestioni, ABI (Italie), VOEIG(Autriche), The Investment Association, Association of British Insurers, TISA (UK), AFG, FFA,AMAFI, FBF, Club Ampère (France), ACA, ALFI (Luxembourg), Assuralia (Belgique), Inverco,UNACC (Espagne), DUFAS (Pays Bas) etc

The member corporate:

• Asset managers: AMUNDI, AXA IM, EDR, Schroders, Fidelity, Blackrock, JPMorgan, NNIP, AvivaInvestors, Carmignac, Vanguard, AGI, Jupiter AM, LBPAM, Union Invesment etc

• Banks / distributors: BNPParibas, DB, Citi, Swedbank, CECABank, SGCIB, KBC, Intesanpaolo,SEB, Allfunds, Gruposantander, Nordea, AEBanca, JPMorgan, ABBL, Credit Suisse, Caixabank,Bankinter, Bancsabadell, Handelsbanken, Natixis…

• Insurers: AXA, Standard Life, OMWealth, PreparVie, Irishlife, Swisslife, Aviva, Intesapaolovita,AG2RLamondiale, Aegon, Allianz, ABNAmro, Generali, NN Group, Nordea, Prudential, MetLife,Basler, CredemVita, Lombard…

More than 300 attendees from 14 countries


IM

Regulations generate huge data flows across the different financial sectors

▪ For PRIIPs, insurers require risks, scenarios, costs etc data from asset managers andbanks.

▪ For MIF, distributors need to define the target markets of the manufacturers products andto communicate their ex ante and ex post costs

The EWG objective is to define standardized data exchange templates

▪ For Solvency II, insurers needed enriched inventories: the EWG elaborated the TPT(Tripartite Template)

▪ For PRIIPs, the EWG set up the European PRIIPs template (EPT)

▪ For MIF, the EWG set up European MIFID template (EMT)

… to work on the implementation of the European regulations…while setting up European standards for data exchanges


IM

The principles to define « useful » data

▪ Required by the distributors regulation and still under manufacturers responsibility

▪ Simple, with the clearest possible definition

▪ Free of intellectual property

▪ Useable across all Europe

▪ Compatible with existing standards

A compliant and dynamic governance

▪ Members work for regulated corporate (no vendor, no consultant)

▪ The agenda is built by the members

▪ The decision process is based on a strong consensus and on the minimization of theobligations.

… with a consensual governanceWhile concentrating on minimizing the number of data to produce


IM

EPT & EMT by the EWG: the European standards forPRIIPS & MIF

53

@uktisa@uktisa

Panel Session: EMTSteve Bennett, Good Conduct Consulting

Ghislain Perisse, AXA IMJohn Dowdall, Managing Director, Silverfinch

@uktisa

Thank You!

TISADakota House

25 Falcon CourtPreston Farm Business Park

STOCKTON-ON-TEESTS18 3TX

www.tisa.uk.com01642 666999

[email protected]

@uktisa

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