Dasym Horizons newsletter is MiFiD II compliant
In order to avoid any compliance issues pertaining to the MiFiD II regulation, Dasym will make the contents of its Horizon newsletter freely available on its website.
Under MiFiD II, free research may cause compliance issues
MiFiD II will come into force for EU member states on January 3, 2018. Amongst others, this guideline for financial institutions will regulate the general ban on inducements. In the Netherlands, such a ban has been in effect for the private sector since January 1, 2014. With MiFiD II, this ban will be expanded to include the institutional market as well.
A complicating factor for readers of Dasym’s Horizons newsletter is that research that can be qualified as so-called “inducement” cannot be freely distributed or received. This rule stems from the fact that research that offers a knowledge advantage has financial value. The legislator wants to avoid this kind of financial favoritism in order to make the entire process more transparent for the end client.
In general, Dasym’s publications do not concern financial instruments, nor are they closely related to any specific sector or market, which might shape opinions about financial instruments in this sector. Nevertheless, it is still the responsibility of the recipients to evaluate each publication and determine whether they are allowed to receive such material.
Dasym publications will be freely available via the website from now on
In order to avoid practical problems and ensure that neither Dasym nor the readers of our newsletter are even suspected of favoritism, we have decided to start publishing our newsletter on our website before distributing them by mail. By publishing our philosophical and practical observations in the public domain, anyone can access them and they lose their monetary value.
With this measure, our newsletter falls under the category of “small non-monetary compensation” (instead of “inducement”), which is not banned. Major financial institutions have interpreted these new guidelines in a similar manner and announced that they will also start publishing their research online.
After the publication of the Horizon newsletter on our website, you will receive our newsletter as usual, along with a link to our website where all our newsletters and publications are available. Readers thus do not have to opt out of our mailing list and can continue to enjoy our sharp analyses in 2018.