FIA EPTA welcomes the opportunity to provide feedback on the proposed MiFID II Quick-fix rules in relation to research on companies seeking alternative financing. Overall, FIA EPTA members believe that the unbundling rules laid out in MiFID II removed an important source for conflicts of interest and has reinforced the independence of research. We note that the market has fully implemented and adapted to research unbundling with clients now accustomed to receiving disaggregated cost information that differentiates between costs attributable to research from those related to execution. It is our view that European capital markets would face an undue risk by disapplying the unbundling requirements and could see the industry going in the wrong direction towards less transparency, additional costs and increased operational complexity. This potential step back puts global firms at odds with requirements in other regions of the world such as the UK (where the positive contributions of unbundling to market quality are clearly recognised) or the US where firms are moving towards more unbundled agreements on the back of the positive effects the unbundling rules have had in Europe.
