I don’t know how to answer the MIFID question
Clients will need to refer to their own Legal and Compliance departments to assess whether they are in scope or out of scope of the MIFID 2 research unbundling requirements before answering this question. In summary, this part of MIFID2 applies to investment firms providing portfolio management or other investment or ancillary services to clients, and will therefore capture asset managers, portfolio managers and some pension fund managers based in the EU or EEA. The UK has also extended the scope to include AIFs and UCITS fund managers based in the UK.
Useful links to the relevant legislation are below:
- EU Delegated Directive (Pdf 344k) – Article 13 addresses Research Unbundling
- ESMA Q&A on investor protection topics (Pdf 766k) – Section 7 addresses Research Unbundling
- AMF guidance on Research Unbundling
- FCA Policy Statement on MIFID (Pdf 5.7M) - Section 7 addresses Research Unbundling. Supplemented by FCA Policy Statement on Changes to UK MIFID's conduct and organisational requirements (Pdf 670k)