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After an initial fright in 2007, the MiFID monster is here again to scare the compliance staff of UCITS management companies and AIFMs (referred to herein as “Mancos”). Whereas 10 years ago the impact was quite limited on Mancos active exclusively in the collective portfolio management of funds without taking on any additional MiFID activity, with MiFID 2 the contamination of their “collective” management activity is real. Indeed, if in 2007 a Manco was required to verify that its counterparties, fund managers and distributors were complying with the new rules binding on them (and notably, at the time, the rules regarding best execution and inducements), this could be dealt with in friendly discussions during due diligences with no threat to the Manco’s business. As such, MiFID was not...
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