23 June 2021
On 23 June, FIA responded to the UK FCA’s consultation on changes to the MiFID conduct and organisation requirements with a particular view on best execution reports (RTS 27 and RTS 28). FIA agrees that the quarterly and annual reports have not achieved intended policy goals. Both reports require firms to obtain a significant amount of data points on a continuous basis at significant cost due to the investments in the required technology and staff to produce these reports in accordance with the standards set out in RTS 27 and 28. FIA agrees that the cost for producing the reports are not justified as clients do only gain a very limited benefit and are generally not interested in these reports. Therefore, FIA is supportive of deleting the RTS 28 requirement (annual report).
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