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On the whole, the SMSG is of the opinion that the draft guidelines are sound and beneficial to the protection of the investor. The SMSG is particularly happy with the approach taken by ESMA to not merely update the previous guidelines in light of the MiFID II, but to also thoroughly re-examine all guidelines and add new guidance where necessary (in particular in respect of roboadvice). Also references to insights of behavioural economics and the insertion of a correlation table are much appreciated. Furthermore the explicit confirmation of the “portfolio approach” to investment advice and portfolio management (para 80-81), consistent with the guidelines on target market, is applauded by the SMSG. However, the SMSG also has a number of general comments.
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