It has been over six months since MiFID II became EU law, and accompanying it has been a series of new, occasionally laborious obligations, which have been imposed on the investment fund industry. Chief among them was a consumer protection requirement requiring manufacturers to perform Distribution Oversight and ensure their funds are being sold to the correct target market audience. Manufacturers must now regularly monitor the activities and practices of their underlying distributors to prevent product mis-selling.
Validating client suitability was previously the role of distributors and intermediaries. But with manufacturers now shouldering responsibility as well, many are being forced to implement changes to their business operating models. The reform process has, however, been slow with 83% of market participants telling an industry study in September 2017 that they were less than halfway ready to meeting the requirements to provide data on target client groups. Even today, many firms are still yet to build proper target market solutions.