FCA has created a new page on its website explaining the basic advice regime under MiFID 2 and the IDD. It explains it needed to update its guidance to firms to explain the impact of these pieces of legislation. In particular, it addresses how it needed to apply some MiFID 2 requirements (or “at least analogous” ones) to Article 3 firms, which has the effect that Article 3 firms can no longer provide basic advice on stakeholder products within the scope of MiFID under the non-MiFID COBS rules and must instead comply with COBS 9A. Similalrly, once the IDD is fully implemented, firms will not be able to sell stakeholder products that are IBIPs under the basic advice rules.
The page also highlights FCA’s guidance on what firms should consider when developing streamlined advice models.