5th January 2017

BBA response to ESMA draft guidelines on MiFID II product governance requirements

The BBA argued it is vital that ESMA sets out its guidance in a manner which both allows National Competent Authorities to interpret, and firms to apply, the proposed guidelines proportionately. While we stress the need to apply proportionality throughout the guidelines, we would draw particular attention to the need for its application where a product is distributed only to professional clients and/or eligible counterparties (ECPs), to the design of the target market, and the need for a proportional approach to the negative target market.

Please read the full response via the link below.