Germany – GVT MiFID/MIFIR Amendment

Germany – GVT MiFID/MIFIR Amendment

On 27 August 2019 GE GVT issued responses to consultation and position papers to EU.

  • Two position papers set out what changes and further steps are needed in short and medium term in investor protection regarding MiFID II/MiFIR and PRIIPS regulations.
  • Consultation showed discontent, desire for early refit covering certain requirements.
  • Respondents strongly criticised breadth of MiFID/MiFIR, implementation costs, short timeframe for implementation, insufficient coordination with other legislation (PRIIPS).
  • In future, more attention should be given to ensuring the proportionality of provisions.
  • Sufficient dynamic implementation periods of at least 18 months following publication.
  • GE GVT proposes 2-step approach: near-term correction of minor, mainly technical deficiencies within coming months and more work by EC on more fundamental and contentious issues, if necessary on the basis of further in-depth analysis and studies.