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MFA and AIMA Submit Joint Comments to French AMF on MiFID II Dealing Commission Consultation

On October 28, MFA submitted joint comments with AIMA to the French AMF in response to its consultation on rules for dealing commissions under MiFID II. The letter expresses our general support for the proposed guidance, including the flexibility provided for certain aspects of operating a research payment account, which will allow managers to design their research payment methods in a manner most appropriate for their businesses. The letter also supports the proposed approach to corporate access that would regard introductory services as a minor non-monetary benefit, and higher added value services as research that could be funded through the research payment account. Finally, the letter explains how fixed income research differs from equity research, and recommends that the AMF include fixed income research as a minor non-monetary benefit, and also seeks guidance to help firms comply with both the new EU rules and existing U.S. soft dollar requirements.