On Tuesday 28 January, AIMA submitted a response to the European Securities and Markets Authority's (ESMA) consultation paper on amendments to Article 13 of the MiFID II Delegated Directive (payment for research requirements). 

The consultation paper was published in light of changes being introduced by the Listing Act Directive to enable joint payments for execution services and research. ESMA had been requested to provide technical advice to the European Commission on the implementation of the amendments to MiFID II (and the Prospectus Regulation and Market Abuse Regulation) in the context of the Listing Act Directive. ESMA consulted on which approach to take to changes to the Delegated Directive: (i) no changes; (ii) introduce detailed requirements for the three payment options; or (iii) introduce high-level requirements which better align the Delegated Directive with the three payment options offered in the Level 1 text. 

AIMA's response (attached) agrees with taking a high-level approach to changes to the MiFID II Delegated Directive but disagrees with ESMA’s proposal to require firms, as part of their annual assessment, to include a comparison with potential alternative research providers.

If you have any questions on the consultation, please contact Aniqah Rao.