The SMSG’s overall view of these guidelines is positive. The guidelines provide guidance and establish a framework to define the target market for investment products under MiFID II and in doing so, reduce the risk of miss-selling. At the same time, they are not overly complicated.
Nevertheless, the SMSG has some focused remarks. A major issue refers to the respective role of distributor and manufacturer and the communication between both. We are concerned that some of the guidelines are feasible within the context of a small market where “everyone knows one another” (distributors and manufacturers), but are more difficult to implement in the context of a large market. This would be most regrettable, as the guidelines should facilitate a European Capital Market Union, rather than provide barriers for it. Several of our remarks, in particular with regard to distributors and manufacturers, reflect this concern.
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