Art. 24 of MiFID II Art. 12(2) of the MiFID II Delegated Directive Art. 12(3) of the MiFID II Delegated Directive Art. 13 of the MiFID II Delegated Directive
Is a free trial period of research services acceptable when it is provided in relation to portfolio management or advice on an independent basis?
Answer 12
Based on Article 13(1) of the MiFID II Delegated Directive, research by third parties to investment firms providing portfolio management or other investment or ancillary services to clients shall not be regarded as an inducement if the investment firm pays for it, either out of its own resources or through payments from a separate research payment account controlled by the investment firm.
In the case of a free trial period, the investment firm does not pay for its access to research. Hence, its access to third-party research under a free trial period is qualified as an inducement (a non-monetary benefit) where it is provided in connection with the provision of an investment
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