Art. 62 of the MiFID II Delegated Regulation
When fulfilling the obligation to report on a portfolio depreciating by the 10% threshold, does the firm need to report if a portfolio value drops by more than 10% as a result of the client making cash withdrawals?
Answer 2
The obligation is to report if the overall value of a portfolio, as evaluated at the beginning of each reporting period (usually every three months), depreciates by 10% and thereafter at multiples of 10%. When cash withdrawals are made from a portfolio, the value of the managed financial instrument or funds is reduced by the amount of the client money transferred; but the overall value of the portfolio, as evaluated at the beginning of the previous reporting period, includes the value of the cash withdrawn. So, if clients withdraw cash from a portfolio, until a periodic statement is provided that discounts the cash withdrawn, when calculating the overall value of a portfolio, to see whether the 10% thresholds are exceed
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