ESMA Q&A 1812 — Q&A — Post-sale reporting [Answer Published]

Post-sale reporting

Question

For the purpose of Article 62(1) of the MiFID II Delegated Regulation, if the same threshold is exceeded again and again during the same reporting period, should the firm report the fact to the client each time the threshold is exceeded?

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Answer

[ESMA 35-43-349 MiFID II Q&As Investor protection Ch. 8, question 12]

No, ESMA’s view is that no new information is needed for the purpose of Article 62(1) of the MiFID II Delegated Regulation if no new threshold is exceeded during the same reporting period.

EXAMPLE:

Date

Value of the portfolio

Change in value of the portfolio

Obligation to report (in line with Article 62(1) of the MiFID II Delegated Regulation?

3 Jan 2018

100,000 €

10 Jan 2018

90,000 €

Depreciation of 10%

Obligation to report

25 Jan 2018

92.000 €

Increase of 2%

No obligation to report

27 Jan 2018

89,000 €

Additional depreciation of 3%

No obligation to report

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Source: ESMA original document