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EIS/SEIS & MiFID II

luisamatoluisamato Member
in General

Hi all,

I wondered if anyone knew the rules surrounding EIS/SEIS under MiFID II and whether we are required to produce cost disclosures on this?

We have contacted a number of our providers who have pushed back and said their fund is exempt under MiFID II or that they are not currently going to report on this.

Appreciate any thoughts on this.

Luis

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Comments

  • JonaJona Member

    This doc https://octopusinvestments.com/adviser/adviser-centre/document-library/octopus-mifidii-guide-advisers/ includes EIS as an "investment service" - so will require reporting.....

    If the EIS is a discretionary portfolio then don't see why MiFID would not apply.....

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  • benjaminfabibenjaminfabi Moderator

    Hi,

    I produce estimated ex-post and ex-ante figures for EIS and VCT in the same way as I do for all other investments.

    I have my own methodology to produce these disclosures in a consistent format (even if platforms are sending out their own). So even if something isn't caught by Mifid II (like a personal pension), the adviser review document reports the costs of all assets in the same way.

    My simple methodology for EIS is:

    Ongoing product costs:
    Average of opening and closing value (opening value is net of any initial charges), multiplied by:
    Quoted total ongoing costs of EIS from provider literature, multiplied by:
    Reporting period based on YEARFRAC (excel formula) using opening and closing value dates.

    Initial costs:
    Closing value divided by opening value (net of initial costs), multiplied by initial costs.

    Benjamin Fabi 
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