MiFID II: Target market and complexity
Under MiFID II, product manufacturers and distributors are required to define their target investor markets and take steps to ensure that products end up only in the hands of the intended market, with products being defined as either complex or non-complex.
Target market
Ensuring products end up only in the hands of the intended target market necessitates extensive two-way information-sharing between advisers and product providers.The rules also require ongoing assessment to take place as any change in the objective or charges for a fund could trigger a review of its target market.
Artemis has participated as a member of the Fund Manager, Intermediary and Distributor Working Group (FIDWG), an industry working group of members active across European jurisdictions. The FIDWG group has produced the Target Market Population & Decision Guide (PDF, opens in a new window) to assist firms in applying and interpreting the target market framework which forms part of the EMT; Artemis has adopted the approach set out in the guide.
Complex products
Only ‘non-complex’ products are permitted to be made available to private investors without any advice or suitability checks.
In accordance with Article 25(4)(a) of the MiFID II Directive, all Artemis UCITs funds are classified as non-complex.
We have applied the tests set out in article 57 of MiFID II to our non-UCITs funds and all of these also meet all the necessary criteria to be classed as non-complex.
| UCITS | Non-UCITs |
|---|---|
| Unit trusts | NURs |
| OEICs | Investment trusts |
| Luxembourg-registered SICAVs |