Mark Aldous, head of managed services for Delta Capita, discusses product governance and the need for more cooperation between manufacturers and distributors before the 3rd January 2018.
Buried within the vast array of complex MiFID II legislation is a simple but potentially troublesome requirement to formalise the way in which financial products are developed, designed and their target market is identified based on customer needs. Simple, because most firms already have product development controls in place and will consider suitability and appropriateness as one of their core conduct policies. Potentially troublesome because compared to the heavy lifting in other areas of MiFID II, some have taken the view that this part of the legislation would be relatively easy to implement. And with less than three months to go, the complexities of operating under the prescriptive requirements in the delegated acts have started to come to the surface.