MiFID II lays down a number of product governance requirements (in Articles 16(3) and 24(2) predominantly) and states that the requirements on product governance apply without prejudice to any assessment of the appropriateness or suitability to be subsequently carried out by the firm while providing services to their clients.
The target market requirements apply to firms who manufacture products and to the distributors of those products in different ways – representing the different roles each plays in the product distribution lifecycle.
The obligation to identify the target market (and ensure the product is distributed in accordance with that) is not substituted by an assessment of suitability or appropriateness. Target market assessment has to be in addition to and before the suitability or appropriateness assessment.
The new MiFID II framework applies to both the product development and sales process. “Manufacturer is defined as investment firms that create, develop and issue the launch of new financial instruments … Whilst investment firms that offer or sell financial instruments and services to clients should be considered distributors”.
The responsibilities of distributors are to decide the target market for the financial instrument, regularly review financial instruments against their target market to ensure that they are “fit for purpose” and obtain relevant information from manufacturers. Firms that work with others are required to share information with other firms within the product cycle chain.
Grandis Securities Ltd has a policy in place to ensure that both our responsibilities towards you and our product governance obligations are met.
We are required to assess and define a target market for the investment products manufactured for, distributed or sold to you.
In our role as product manufacturer and/or distributor (seller) we will assess investments periodically and we will share information on investments so that we can take any appropriate steps to improve outcomes for you as our client (or the end client).
When we make different products and services available to you we will do so in accordance with the Rules relating to the manufacturing and distribution of investments products.