Subject: MiFID II Research Provisions
From: Adam Jacobs-Dean, Managing Director, Global Head of Markets Regulati
Affiliation: AIMA

Jan. 17, 2019

Good morning,
We noted with interest your call for input regarding the MiFID II Research Provisions. This is a topic that AIMA (global trade association representing the hedge fund industry) has worked on extensively in the last couple of years. 
I thought you might be interested in the results of a member survey that we carried out last year – see attached.  This has some potentially helpful stats about how firms pay for research (split by asset class), and what they have seen in terms of quality and pricing etc. It might be that some of the points have shifted somewhat given when we undertook the survey, although my sense is that things are reasonably stable. A lot of firms are waiting for the findings of an on-going FCA thematic review of this topic, which may result in further comment from the regulator about their expectations in this area, noting that research forms part of a broader set of provisions regulating ‘inducements’. The application of these rules to other services such as cap intro, consulting, and corporate hospitality remains a matter for discussion and debate within industry.
Very happy to discuss further if you have any questions on this topic. I appreciate that this work is probably on hold at this particular point in time given the shutdown, but I’d be happy to arrange a call on this when work resumes.

Adam Jacobs-Dean 
Managing Director, Global Head of Markets Regulation 

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(Attached File)