FCA has published the minutes and slides from a MiFID 2 conduct forum it held on 18 April. The forum attendees were industry associations and a few firms they suggested, and the forum covered product governance and disclosure of costs and charges. FCA invited questions in advance, and its responses included:

  • that it is still assessing how to apply product governance rules to non-MiFID 2 business;
  • how it expects firms to apply the proportionality principle in determining the level of detail needed to assess target markets, and on assessing execution-only products;
  • how firms should deal with non-EEA products and providers;
  • how distributors and manufacturers should work together;
  • how FCA will align MiFID 2 requirements with the Financial Advice Market Review;
  • generally, that MiFID 2 is likely to bring more prescriptive rules than FCA currently lays down on product governance, thus limiting flexibility;
  • noting the likely time discrepancies for costs disclosures required under key directives to take effect;
  • considering the disadvantages of a standardised format for disclosure, where MiFID 2 does not require it; and
  • using ESMA guidance in dealing with ongoing disclosure requirements.

(Source: FCA publishes MiFID 2 conduct forum details)