FIA's European E-Trading Committee - in cooperation with AFME, AIMA and MFA - have produced a template of questions for use by investment firms providing direct electronic access to their clients, as required under Article 22 of RTS 6.
An investment firm that provides direct electronic access is responsible for ensuring that clients using that service comply with the requirements of MiFID II and the rules of the trading venue. An investment firm offering DEA is required to carry out a due diligence assessment of its prospective DEA Clients to ensure that they meet the requirements set out in RTS 6 and the rules of the trading venue to which it offers access.
The purpose of this template is to allow both the DEA Provider and Client to utilise a standardised set of relevant/necessary checks. Whilst this template may allow DEA Providers to use a common set of questions for their DEA Clients, it is not intended to be uniform across all firms, and DEA Providers may omit or add questions appropriate to the services that they provide to DEA Clients, as well as any additional questions pertinent to local regulations under the jurisdiction of the DEA Provider.
FIA will shortly publish additional annexes to the template for a standardised set of questions regarding topics - such as algorithmic trading - that are not explicitly required under Article 22 of RTS 6 but investment firms may wish to incorporate into their due diligence processes.
For further information please contact Tessa Jones or Greg Wood.
