Q&A: MiFID II: Client information reporting critical for U.S. managers

IMP's Jane Stabile and Jon Gold was interviewed for a Q&A about the impact of MiFID II on US asset managers. Read an excerpt:

Danielle Kane (DK): How is the EU’s Markets in Financial Instruments Directive, known as MiFID II, relevant to U.S. investment managers?

Jane Stabile, president (JS): The law applies differently based on what you do. For example, if you’re a manager and have clients that you’re trading for that reside in the EU, then all of those accounts are subject to MiFID II whether they are funds or separately managed accounts.

Other examples include if you’re an EU subsidiary, if you’re marketing cross-border products to European clients, or if you’re providing sub-advisory services even with no physical presence in Europe.

Jon Gold, managing director (JG): Even if you’re a U.S. firm trading for U.S. clients and using an EU exchange, that venue is going to ask questions about your U.S. clients because they are going to have to report that. So even if there’s no applicability to you as a U.S. firm, you will still have to provide this type of information to trade on those venues.

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