ALFI responds to the ESMA consultation regarding the review of the Guidelines on MiFID II product governance requirements

The main proposals in ESMA’s draft guidelines relate to

• the specification of any sustainability-related objectives a product is compatible with;
• the practice of identifying a target market per cluster of products instead of per individual product (“clustering approach”);
• the determination of a compatible distribution strategy where a distributor considers that a more complex product can be distributed under non-advised sales;
• the periodic review of products, including the application of the proportionality principle.

View the ALFI response.