MiFID II Costs & Charges Workshop 4th September 2019 Jeffrey - - PowerPoint PPT Presentation
MiFID II Costs & Charges Workshop 4th September 2019 Jeffrey - - PowerPoint PPT Presentation
MiFID II Costs & Charges Workshop 4th September 2019 Jeffrey Mushens Technical Policy Director, TISA 1. What is Costs & Charges? What the Directive says Who it affects What it covers When it has to be done What has to
Jeffrey Mushens
Technical Policy Director, TISA
www.tisa.uk.com 3
- 1. What is Costs & Charges?
- What the Directive says
- Who it affects
- What it covers
- When it has to be done
- What has to be done
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- 2. What the Directive says
- Article 24(4)
- The information about all costs and charges, including costs and charges in connection with the investment service and
the financial instrument, which are not caused by the occurrence of underlying market risk, shall be aggregated to allow the client to understand the overall cost as well as the cumulative effect on return of the investment, and where the client so requests, an itemised breakdown shall be provided. Where applicable, such information shall be provided to the client on a regular basis, at least annually, during the life of the investment
- Article 50 of the Delegated Regulation
- The aggregated costs and charges shall be totalled and expressed both as a cash amount and as a percentage.
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- 3. Who it affects
- MiFID businesses
- Some UCITS firms are not MiFID businesses, but their
customers may be
- Product manufacturers
- Platforms
- Advisers
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- 4. What it covers
- Pre sale disclosure (ex ante)
- Post sale disclosure (at least annually), but
- Portfolio management services clients at least
quarterly (see Article 60 Delegated Regulation)
- All costs
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- 5. What are all costs?
- See Appendix 1
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- 6. When it has to be done
- ex ante -Appropriate information shall be provided
in good time to clients or potential clients
- ex post -such information shall be provided to the
client on a regular basis, at least annually, during the life of the investment
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- 7. What has to be done
- All costs and charges, shall be aggregated
- Cumulative effect on return of the investment where the
client so requests, an itemised breakdown shall be provided.
- At least annually
- The aggregated costs and charges shall be totalled and
expressed both as a cash amount and as a percentage.
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- 8. Some current issues
- Cumulative effect of charges on returns
- Calculation of transaction costs
- Arrival price methodology (implicit costs/slippage, half spread,
etc)
- Dilution levy
- What happens when the fund manager is outside the EEA?
- Property funds.
- ESMA call for evidence.
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