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Articles by Bobby Johal
Corporate Governance: You Have to Be Uber Careful
Under pressure to meet stringent governance requirements, investment managers could have more in common with the Uber driver than you might think. As Uber sweats over its impending court trial, investment firms, with less than 100 days until MiFID II implementation, need to ensure they brush up on their company culture to avoid a similar fate.
MiFID II for Asset Managers: Product Governance
Obligations are split according to whether a firm is involved in the manufacture or distribution of products. The table below outlines what the new obligations are in respect to both product manufacturers and distributors. While there is overlap across these parallel sets of responsibilities, there are also aspects that are unique to each.
MiFID II for Asset Managers: Communications Record Keeping
What Needs to be Recorded? For firms obliged to keep electronic records of communications, the MiFID II obligations will require that records are kept for at least five years (and up to seven if requested by National Competent Authorities), which is a significant increase from the six months of records currently required by the FCA. However, it is not just the length of the retention period that threatens to be problematic, but also the scope of what needs to be recorded.
MiFID II for Asset Managers: Research Unbundling
While the stated principles behind research unbundling may seem fairly straightforward, the path to achieving those principles is anything but. From the perspective of investment managers, the most pressing priority (should the FCA confirm its current thinking) will be to decide how research will be funded going forward.
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