At a pan-industry seminar held by TISA on Tuesday 29th September, the key issues around retail themes and interim recommendations of the working groups were set out and discussed.
MiFID II is now in implementation phase which TISA says is the time for the industry to consider what good practice could or should look like and to help provide guidance.
TISA has identified the following key themes which it believes will require the most legislative attention:
- Development of a standard for appropriateness.
- Product governance – the relationship between product manufacturers and distributors.
- Development of standardisation and templates.
- Definition of the target market.
- Need for common standards in messages, data sets and language used between firms.
- Issues around data protection.
Jeffrey Mushens, Technical Policy Director of TISA said:
“MiFID II is a significant piece of regulation which will have a major impact on the market and our members. As a result, we’ve established TISA MiFID II Product Governance and Appropriateness Project Working Groups to lead on the key issues and themes we have identified. These groups will establish standardised processes, common definitions and market practices that meet the needs of firms and customers, and that satisfy the regulatory obligations placed on firms.
“TISA will continue to take the lead, working with trade associations where appropriate, to help our members and the wider industry understand the full implications of MiFID II and how to best prepare their businesses for the change. We are keeping the FCA fully informed with the hope they will take a full interest in these two critical issues moving forward. This is a rare window of opportunity to influence regulatory thinking and we hope the initiative will be well received.
“The support and response we have received from our members and the wider industry has clearly demonstrated why these issues are so critical. And, this is why we are engaging with the FCA who will be writing and implementing future rules which will govern both appropriateness and product governance.”
