Mifid 10% drop notifications
Was told yesterday by our compliance people that we don't need to issue 10% drop notifications as the FCA has extended the relaxed rules until the end of the year. The following is from the FCA website and, unless I'm reading it wrong, it suggests that we do.
During this period, we won’t take action for breach of COBS 16A.4.3 UK for services offered to retail investors provided that the firm has:
• issued at least one notification in the current reporting period, indicating to retail clients that their portfolio or position has decreased in value by at least 10%
• informed these clients that they may not receive similar notifications should their portfolio or position values further decrease by 10% in the current reporting period
• referred these clients to non-personalised communications, perhaps made available on public channels, that outline general updates on market conditions (these could contextualise potential drops in portfolio or position value to help consumers meet their objectives, rather than making impulse decisions about their investments) and
• reminded clients how to check their portfolio value, and how to get in touch with the firm