Since the implementation of the European MiFID Template (EMT) at the beginning of 2018, the industry has been working on changes in the background which aim to enhance the EMT data transfer capabilities.
In October 2018 FinDatEx (formerly known as the European Working Group) published the EMT Version 2 however its use was only intended for structured products, not funds. FinDatEx released the third version of the EMT template on 10 December 2019, for use by both structured and fund products. This document provides an overview of the changes for fund products and expectations on the transition plan for the industry.
When did it come into effect / what is it?
The MiFID II Regulation came into force on 3 January 2018 with a key focus on enhancing cost transparency to investors and ensuring the right product types fall into the hands of the right investor (enhanced target market definition). Product manufacturers now need to clearly transmit this information to the distributors of their products, allowing the distributor to effectively apply the MiFID II requirements to their sales process.
FinDatEx is a joint structure established by representatives of the European financial services sector with the view to coordinate, organise and carry out standardisation work to facilitate the exchange of data between industry stakeholders. Ahead of the roll out of MiFID II the body worked on the EMT version 1 and published their first template in late 2017. This template allows for a standardised transfer within from manufactures to distributors of product costs and product target markets.
What prompted a new version to be published?
For the most part, once product manufactures had completed one cycle of the EMT population, the template was a success and allowed distributors to collate the target market information and costs for the products they are selling. There were some difficulties in the beginning and also those which emerged at a later date which prompted for a revised version to be released, some examples below:
- The wording surrounding the target market sections was sometimes difficult to understand, and left manufacturers unsure about what to answer at times.
- The dates displayed in the EMT caused confusion at times, especially when cost figures were calculated as at different dates and using different time periods.
- The question of using a value of ’99.99’ to indicate a null or non-applicable meaning for performance fees was an area which caused much back and forth at the beginning.
- Distributors in receipt of an EMT from the manufacturer sometimes and other times from a service provider caused confusion when the distributor needed to query the data being provided.
Overview of changes
General File Changes
- Dates should now be included for each part of the EMT and reflect the period for which the data is covering.
- Field name changes and field descriptions updated to help with understanding the meaning.
- Mandatory / Optional / Conditional / Indicative field requirements updated in a number of areas.
Target Market Changes
- Client Objectives and Needs now includes an ‘ESG’ specific field (previously rolled into the ‘Other Specific Investment Need’ field).
Cost Section Changes
- Borrowing costs to be included going forward if applicable (both ex-ante and ex-post).
Static Information Changes
- New clarity added to show who the EMT producer is along with contact information for both the producer and manufacturer to allow the distributor to reach the correct party when queries arise.
- The financial instrument product type field has been broken down into more classifications, previously just UCITS or NON UCITS for fund products.
- New indicators added for classes with performance fees and distribution paying arrangements.
A German categorisation code field has been added to be populated if the product is sold in Germany.
Implementation of EMT version 3
FinDatEx announced the new template on 10 December 2019 and have given a final implementation deadline of 10 December 2020. They note that they would like to see the industry move across to the new version in a staggered approach during 2020 and that both recipients and providers of the EMT should have capability to produce either version until 10 December 2020.