Besides responding to the specific questions Finance Denmark send the following messages.
- Focus should be on establishing a simpler and more proportionate cost disclosure regime which provide relevant and comparable information to benefit end-clients. Increased harmonization and supervisory convergence are important, but this should not lead to more complex and overly detailed rules.
- The call for evidence focuses on the disclosure rules relating to inducements. Many of the challenges however relate to other areas of the regime such as divergent legal interpretations by competent authorities regarding the quality enhancement regime, the principle of proportionality and application to primary market transactions. Whilst noting that the mandate to ESMA is restricted to disclosure, we would welcome a more extensive study on the impact of the inducement rules in MiFID II.
- It should be noted that the industry is heavily engaged in self-regulatory work through FinDatEx to create a better and common standard for data exchange related to cost & charges and target market data. One of the consequences of the MiFID II cost & charges regime is that this has become a truly massive data exchange exercise between manufacturers and distributors. The industry’s self-regulatory work will take some time to finalize and implement, and we urge the regulator to be aware of that.
