Answer 3

In order to be able to demonstrate to NCAs how they meet their obligations to the issuer client when providing underwriting and placing services, as well as their obligation to manage conflicts of interest between different clients or groups of clients, firms should have a process to record allocation decisions at material stages in the allocation process.

Records of allocations decisions should include:

a. The firm’s overarching allocation policy under Article 40(4) in force at the time of the commencement of the service;

b. The firm’s initial discussion with the issuer client and the agreed proposed allocation per type of investment client, as required by Article 40(5);

c. The content and timing of allocation requests received from each investment client with an

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