ESMA has added 10 new questions to its Q&As on investor protection under MiFID 2 and MiFIR. The new questions cover:
- timing requirements for execution reports;
- how to report when orders are sent for execution to different entities within a group;
- inclusion of ECP transactions within data execution venues publish;
- how investment firms operating OTFs should set their execution policies;
- the interpretation of the terms “passive” and “aggressive” orders;
- whether arranging meetings for investment firms with corporate issuers can be considered as research for the purposes of the RPA model;
- how to categorise macro-economic analysis in terms of research;
- how firms providing portfolio management or independent investment advice should treat research relating to fixed income, currencies or commodities;
- the approach firms should take to ensure their research budget is used in the best interests of clients; and
- how the estimated client research charge should be presented.