Can the service of a third party arranging meetings with the management of a corporate issuer for an investment firm ('corporate access’) be considered as research that can be paid for from an RPA under Article 13(1)(b) of the Delegated Directive, and if not, how should firms providing independent investment advice or portfolio management services treat such services?

Answer 7

Recital 28 provides a definition of research for the purpose of the RPA model. Arranging a meeting itself is not providing material or services which "explicitly or implicitly recommend or suggest an investment strategy and provide a substantiated opinion as to the present or future value or price of such instruments or assets" so does not appear to be 'research’ and should be considered a discrete service.

This does not preclude an investment firm that arranges such meetings, and also supplies research and execution services, from being paid for research services from an RPA, but the firm should ensure their pricing and payments received from firms purchasing its research are not subsidising a charge for the corporate access (concierge) service. This is consistent with Article 13(9) of the Delegated Directive, which applies to firms providing execution services, which specifies that "the provision of each other benefit or service by the same investment firm to investment firms established in the Union shall be subject to a separately identifiable charge."