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Version date: 28 March 2019 - onwards

Question 24 Ex-ante information for the service of portfolio management [Last update: 28 March 2019]

Art. 24 of MiFID II Art. 50(2) and (5) of the MiFID II Delegated Regulation

How should the ex-ante costs and charges disclosure requirements be applied to the service of portfolio management?

Answer 24

In accordance with Article 50(5) and Recital 75 of the MiFID II Delegated Regulation, an investment firm must inform the client, in good time before the provision of the investment service of portfolio management, about the costs and charges relating to (i) the investment and ancillary service(s) to be provided (service costs) and to (ii) the financial instrument(s) in which the client’s portfolio could be invested in accordance with the mandate given by the client (product costs).

Due to the nature of the service of portfolio management (management on a discretionary client-by-client basis), no cost disclosure is due in relation to each investment decision taken by the firm. However, ex-ante information about costs and charges should be provided before the firm starts providing the

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