We use cookies to track usage and preferences. See Cookie Policy
Pocketmags Digital Magazines
IT
Pocketmags Digital Magazines
   You are currently viewing the Italy version of the site.
Would you like to switch to your local site?
Digital Subscriptions > The Hedge Fund Journal > Issue 127 - October 2017 > Cross-Border Implementation of MiFID II Research Provisions

Cross-Border Implementation of MiFID II Research Provisions

JULIAN RAINERO, BRIAN T. DALY, MARC E. ELOVITZ and ANNA MALEVA-OTTO, SCHULTE ROTH & ZABEL

On Oct. 26, 2017, the US Securities and Exchange Commission (“SEC”) published three temporary no-action letters providing US broker-dealers and investment advisers relief in the conduct of their business activities with entities subject to the European Union’s Markets in Financial Instruments Directive (“MiFID II”), which will go into effect on Jan. 3, 2018. The no-action relief, described in further detail below, permits:

(1) US broker-dealers to receive “hard dollar” payments from research payment accounts (“RPAs”) from EU asset managers subject to MiFID II without having to register as an investment adviser under the Advisers Act;

(2) Investment advisers to continue to aggregate client orders while accommodating differing research payment arrangements that will be required under MiFID II, notwithstanding certain provisions and obligations of Section 17(d) of the Investment Company Act of 1940 and Rule 17d-1 thereunder and Section 206 of the Advisers Act; and

(3) Investment advisers to rely on the “soft dollar” safe harbor provided by Section 28(e) of the Exchange Act when the adviser makes payments for research to an executing broker out of client assets — alongside payments to the executing broker for execution — with the research payments credited to an RPA administered either by the executing broker or a third-party administrator.

READ MORE
Purchase options below
Find the complete article and many more in this issue of The Hedge Fund Journal - Issue 127 - October 2017
If you own the issue, Login to read the full article now.
Single Issue - Issue 127 - October 2017
€129,99
Or 12999 points
6 Month Digital Subscription
Only € 140,00 per issue
€699,99
Or 69999 points

View Issues

About The Hedge Fund Journal

Informing the Hedge Fund Community. With access to some of the industry’s biggest names and an astute and talented group of writers and contributors, The Hedge Fund Journal has established itself as a trusted source of information on the hedge fund industry.
Modalità di pagamento Pocketmags Payment Types
A Pocketmags si ottiene Fatturazione sicura Ultime offerte HTML Reader Regali Loyalty Points