Over recent months, AMAFI has been working to formally set out its thoughts and proposed amendments for the revision – or refit – of the three levels of regulation that form the MiFID 2 framework. The aim, based on experience gained in implementation over the last two years, was to specify the points where adjustments looked necessary, without calling everything into question, given the huge efforts to adapt already made by the industry.

AMAFI has now finalised its position in a document (AMAFI / 20-03) that is available in French and English and that addresses the framework’s two key areas, namely market structure and investor protection. Regarding market structure, the main issues of concern involve territoriality, the cost of market data, the OTC derivatives regime and the funding of research on SMEs. With provisions on product governance and cost and charge disclosures, the challenge is to streamline the arrangements as far as possible and introduce more proportionality according to financial instrument and client category, notably to recognise the needs of the wholesale segment. Awareness-raising initiatives will be organised in the first half of 2020 on this basis.

AMAFI also plans to draw on the position paper on this issue prepared by EFSA, a pan-European discussion forum for AMAFI and its sister associations.