On February 15, MFA jointly submitted with AIMA the attached letter in response to the UK FCA’s fourth consultation on MiFID II. In the consultation, the FCA proposed to require firms to provide investors with a periodic breakdown of payments made to specific research providers. In the letter, we express support for the objective of ensuring sufficient transparency to fund investors so they can make fully informed decisions. However, we are concerned that disclosure of the amount each research provider was paid during the preceding period would introduce potential competitive issues for managers and research providers. In addition, disclosure of this type of information is generally not of interest to fund investors. We believe that the policy objective of ensuring investors are able to monitor and query levels of research spending would be achieved most proportionately by providing them with a single aggregated figure for research spending during the account period.
