Eurosif response to ESMA consultation on the review of the guidelines on MiFID II product governance requirements
On Friday 7th of October, Eurosif submitted its response to the consultation on the review of the guidelines on MiFID II product governance requirement [link]. Eurosif largely endorses the proposed additions made to the ESMA guidelines on the identification of a potential target market by the manufacturer. However, we have a number of suggestions to enhance the applicability of the Guidelines and ensure they build upon the recently published Guidelines on certain aspects of the suitability requirements. Amongst them:
- Eurosif agrees, for the most part, with ESMA that sustainability factors should not be a basis, in and of themselves, to limit the target market for a product.
- The manufacturer should identify and describe the sustainability-related objectives with which a product is compatible based on its features, as clients will likedly include sustainability-related goals as part of their broader objectives and needs.
- In the interest of facilitating the distribution of products with sustainability-related features or objectives, the terminologies used by manufacturers and distributors should be harmonised to the greatest extent possible.
- Applying the concept of minimum proportion to financial products for the purposes of the MiFID II provisions on gathering client sustainability preferences is practically challenging due to limited and/or unreliable data from investee companies and divergent interpretations of ‘sustainable investment’ as envisaged in Article 2(17) of the SFDR.
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