Clifford Chance

US SEC Issues Three ‘No Action' Letters on MIFID2 Research Unbundling

26 October 2017

Today the US Securities and Exchange Commission issued three related no-action letters that collectively provide relief to US market participants who are impacted directly or indirectly by MiFID2. In parallel, the European Commission issued an FAQ offering guidance to portfolio managers subject to MiFID2 and non-EU broker-dealers that provides flexibility in the types of payments that can be made.

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