SEC staff requested feedback on the impact of recent EU rules on research and three related SEC no-action letters. Comments must be submitted by January 31, 2019.
To assist market participants in their efforts to comply with the EU Markets in Financial Instruments Directive ("MiFID II") research provisions with U.S. securities laws, the SEC issued three no-action letters. The letters address requirements on investment advisers to, among other things, separate out payments for research from the commissions paid to broker-dealers for execution services. Chair Jay Clayton stated that "it is important to have data and other information about how MiFID II's research provisions are affecting broker-dealers, investors and small, medium, and large issuers, including whether research availability has been adversely affected."
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