Our Secondary Markets Expert Group contributed to our response to the ESMA consultation regarding its draft guidelines on MiFID II product governance requirements.
We encouraged ESMA to expand on its views in paragraphs 17 and 18 of the background on the draft guidelines to explicitly clarify that public market, plain vanilla securities are – rather than “can be” – compatible with the needs and characteristics of the mass retail market, with or without professional advice.
We commented that clarifying this will ensure that the requirements for product governance under MiFID II remain consistent with the Commission’s desire to establish a Capital Markets Union that supports the funding of SMEs in public equity markets across Europe.
