|Of relevance to:||Managers of UK UCITS|
|Key date:||Has sufficient notice been given to investors for when MiFID II comes into force on 3 January 2018?|
MiFID II requires EU portfolio managers to either bear investment research costs directly from the firm’s own resources, or, if they choose to charge clients for research, adequately disclose and account to their clients for that expenditure.
If you are managing a UK authorised fund classified as an Undertaking for Collective Investment in Transferable Securities scheme (“UCITS”), Non-UCITS Retail Scheme (“NURS”) or a Qualified Investor Scheme (“QIS”) and are planning to pass the costs for research to the fund, then you should have applied to the FCA by 30 September 2017 in order for the change to be effective when MiFID II comes into force on 3 January 2018; 60 days’ notice to investors is required before the change can take effect.
It is crucial your firm makes a decision regarding investment research costs and any relevant amendments and notifications as soon as possible.