MiFID II Ex-ante disclosure for fund switches/portfolio changes
Hopefully you can help with a discussion we are having in our office. We work on a bespoke advisory basis and generate personallised recommendations and portfolios for all of our clients.
Our original understanding of the MiFID II rules was that an ex-ante projection was required to be produced at the point of every change to the portfolio, so a switch from Fund A to Fund B within an ISA portfolio would require a projection to be produced and included in the recommendation. This has proved extremely time consuming given the volume of recommendations we get through.
How are other people approaching this issue? As it is a switch within a product for which an Ex-ante projection was provided when the investment was made, do we even need to provide another Ex-ante projection as any changes will be picked up in the Ex-post reporting?