CSS Solution Silverfinch Welcomes TISA & PIMFA MiFID II Initiative

In late June, PIMFA, the UK wealth management association and TISA, the Tax Investment and Savings association published the “MiFID II Feedback Template,” to be known as the EFT. They also published a “Distributor Reporting Guide” to assist firms with implementation and understanding.

The two together are the first steps in defining a reporting standard for MiFID II upstream reporting from distributors to fund product manufacturers to allow them to comply with sales suitability reporting based on the target market of products.

In addition to the draft guide a Q&A document was also issued to help distributors make compliant returns to asset managers.

The draft template and guide have been developed by a cross industry working group consisting of TISA, PIMFA, the IA alongside leading asset managers and distribution businesses.

Market feedback on the proposed template closed on July 12. The working group will now meet with the Financial Conduct Authority (FCA) and the European Securities and Markets Authority (ESMA) to inform regulators of the approach in advance of issuing the final versions.

PIMFA & TISA also announced their call for firms across the sector to join a user group to test the template and ensure that it can be meaningfully incorporated into firms.

Silverfinch – a CSS solution – welcomes the approach by both TISA and PIMFA to standardize the reporting requirements from distributors to manufacturers and is already working with clients on the distribution of data using the draft templates. Feedback on testing with live clients will be provided to the working group by Silverfinch to ensure the industry has a robust solution to the reporting requirements during 2018 and onwards.


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CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.

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