Further to the French implementation of the MiFID II research payments rules to which we responded back in October, the AMF last week published a feedback paper.

The key points include that: (i) collective investment management remains out of scope; (ii) there will be no proportionality for small firms; (iii) further clarification of what constitutes a minor non-monetary benefit will be explored; (iv) corporate access will continue to be split between concierge and intellectual services, but any concierge services that involve an allocation of valuable resources will not be “minor”, thus will have to be paid for directly; (v) there is no need for per-provider breakdown of information for clients on research spend; (vi) CSAs are still authorised insofar as they comply with the RPA rules; (vii) broker votes are not going to be excluded from the regime; and (viii) a manager can have several RPAs. The AMF are also considering whether to publish a guide in 2017 following ESMA’s level 3 work.  If you have any follow up questions, please contact Adam Jacobs, Oliver Robinson or Adele Rentsch.