In their recent response to the European Securities and Markets Authority’s (ESMA) Call for Evidence on Inducements and Costs and Charges Disclosure Requirements under Markets in Financial Instruments Directive (MiFID) II, PIMFA has outlined their concerns about the complexity of these disclosure requirements and the burdens they place on firms seeking to comply with those requirements. Although ESMA suggests that certain difficulties identified with the current regime can best be addressed through further, more detailed rules and mandated presentation formats. |
PIMFA has responded saying that MiFID II should not provide any more detailed rules governing the timing, format and presentation of these disclosures at this current time as well as loading further significant costs on firms. They argue, this would only serve to further confuse consumers, many of whom are less than clear about what the new MIFID II disclosures mean. Instead, if amendments to the MiFID II costs and charges regime are required, they should be subject to a review process that requires detailed consultation, cost-benefit analysis and consumer testing, while also taking into consideration the industry, consumer and supervisory experience of the operation of the current regime to date. Sarah McGuffick, Lead Regulatory Policy Adviser at PIMFA said: “We have made it clear that, if there was to be any hope of MiFID II being applied consistently across the industry, the regulators would need to provide unambiguous and detailed provisions on which firms could base both systems specifications/development. This, in turn, could result in the necessary changes to in-house processes and procedures. The fact that this did not happen has resulted not only in firms incurring huge costs in interpreting and applying regulation but also in their diverting resources away from their most important function, namely the day-to-day servicing of their clients’ needs and wishes.”
Read the full consultation response |
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Specialty GI Pricing Leader | ||
London - Negotiable |
Senior Life Actuarial Assoc or Direct... | ||
Bermuda - Negotiable |
Health Insurance Manager | ||
London/hybrid 2-3dpw office-based - Negotiable |
Principal Actuary - Bermuda | ||
Bermuda - Negotiable |
GI Pricing Analyst | ||
Wales / hybrid 2dpw in the office - Negotiable |
International Investment Manager | ||
Bermuda - Negotiable |
Financial Risk Leader - Bermuda | ||
Bermuda - Negotiable |
Risk Transfer Consultant | ||
Any UK Office location / Hybrid working, 2 days p/w in office - Negotiable |
Senior Life Actuarial Analyst | ||
South East / hybrid 3dpw office-based - Negotiable |
Investment Manager - Credit Risk & Re... | ||
South East / hybrid 3dpw office-based - Negotiable |
Actuarial Project Manager | ||
South East / hybrid 3dpw office-based - Negotiable |
Senior Associate - Trustee Pensions | ||
South East / hybrid 1-2dpw office-based - Negotiable |
STAR EXCLUSIVE: BPA Pricing Actuaries | ||
Flex / hybrid 2-3 dpw office-based - Negotiable |
Ceded Re Pricing Actuary | ||
London - £150,000 Per Annum |
Senior Actuary | ||
London - £180,000 Per Annum |
Financial Reporting in Reinsurance | ||
London / hybrid 2 days p/w office-based - Negotiable |
Home Insurance Director | ||
North West/Hybrid - £140,000 Per Annum |
Head of Long-tail Global | ||
UK/USA - £200,000 Per Annum |
Challenge the pensions industry! | ||
UK Flex / hybrid 2dpw office-based - Negotiable |
Pensions Data Science Actuary | ||
Offices UK wide, hybrid working - Negotiable |
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