Joint Letter in Response to ESMA Call for Comment on MiFID Costs and Charges Disclosure Requirements

On September 5,  MFA submitted a joint letter with AIMA in response to ESMA’s Call for evidence on the impact of the MiFID inducements and costs and charges disclosure requirements. In the letter we recommend: (i) that the disclosure requirements be removed for professional clients or provided only upon request, which would be particularly useful for EU sub-advisors whose sole clients are their respective parent investment management firms, (ii) clarification that slippage costs should not be included in the calculation of transaction costs, (iii) that the costs and charges regime for professional clients not be amended to align with that of retail clients, and (iv) changes to standardize the provision of product fees and costs across PRIIPs and UCITS.