MiFID 2 – Product governance

AMAFI is updating its guide to implementing product governance obligations. The proposed changes seek, among other things, to clarify the relationship between the obligations to regularly review target markets and to identify events affecting the risk/reward tradeoff. Another goal is to introduce, on an optional basis at this stage, recognition of customer environmental, social and governance  preferences, where applicable.

AMAFI is also using the opportunity presented by the update to provide clarification about the framework’s application at the moment of the purchase – not the sale – of financial instruments and about the terminology used in Annex 5 on derivatives. As with previous versions of the guide, AMAFI sent its proposals to the French regulator to provide a basis for bilateral discussions before publishing the document.