Co-operative banks have generally been supportive of the introduction of the ‘Markets in Financial Instruments Directive’ (MiFID) II and its accompanying ‘Markets in Financial Instruments Regulation’ (MiFIR), as they are the legal basis for disclosure requirements that provide end clients with clear, correct and comparable information on all costs and charges relating to the provision of investment services and financial instruments. Having said that, the implementation of these legal texts has not been without difficulties. Resolution of such implementation issues has been an ongoing priority topic for EACB members since entry into force of MiFID II and MIFIR.
In fact, EACB members have carried out a cost-benefit and legal analysis of the implementation issues generated from MiFID II/ MiFIR, even before the publication of this consultation. The analysis was finalised in a whitepaper dated 6 November 2019, titled EACB proposal for a MiFID II Refit: “Towards a more effective framework respecting diversity and consumer choice” and which was publically discussed with the European Commission and members of the European Parliament and permanent representations of the EU Member States in an event held on 20 February 2020.
Therefore, the EACB welcomes this opportunity to participate in the European Commission’s consultation on the review of the MiFID II/ MiFIR regulatory framework which also goes further (in terms of certain topics) than the EACB proposal dated 6 November 2019. Our feedback can be found on the left side of this page.