WMA’s response to ESMA’s consultation on draft guidelines on product governance under MiFID 2 highlights:
- that execution-only firms are not clear on what is expected of them, given the restricted information they hold about their clients;
- the need to stress manufacturers of mass market products should seek only relevant information. WMA thinks the focus should properly be on ensuring that non-mass market products reach only their intended recipients;
- lack of consistency in terminology, when the guidelines describe investors a product is meant for, those who it should never reach, and those in between; and
- concerns over ESMA’s interpretation and understanding of certain other terms and market practices.