MiFID II › Level 3 › Q&A › ESMA
ESMA Q&A 1129 — Q&A — MiFID practices for firms selling financial [Answer Published]
Financial servicesLevel 3Q&AMiFID IIAnsweredOfficial source
MiFID practices for firms selling financial instruments subject to the BRRD resolution regime
Question
Does Article 44a of BRRD 2 apply only if there is an active offering on the part of the firm?
Answer
[ESMA35-43-439 Investor protection BRRD regime Q&A 2]
No. Article 44a will apply independently of any marketing or active offering by the seller of the subordinated eligible liabilities, and whether the transaction has been initiated by the client or the firm (thus, including in case of reverse solicitation).
Source: ESMA original document