No passado dia 19 de Novembro, na reunião do Legal Committe da BetterFinance que teve lugar em Bruxelas, Octávio Viana, presidente da Associação de Investidores e Analistas Técnicos do Mercado de Capitais ("ATM"), apresentou os resultados do inquérito sobre a implementação da DMIF II em Portugal, com análise comparativa sobre a Alemanha, França e Dinamarca.
Os resultados obtidos estão em linha com os obtidos nos países supra referidos, sendo que os investidores portugueses fazem uma apreciação mais positiva dos novos regulamentos do mercado financeiro do que os outros países, principalmente quando comparando com a Alemanha.
A 26 de Novembro de 2019, registam-se aproximadamente 100 respostas ao questionário.
O questionário está disponível até 31 de Dezembro de 2019. Os investidores não qualificados que pretendam responder ao mesmo podem fazê-lo por intermédio desta ligação.
Pode aceder à apresentação supra referida sobre a implementação da DMIF II em Portugal por através desta ligação:
Abaixo encontra a transcrição da apresentação de Octávio Viana, presidente da ATM.
Transcrição da apresentação sobre a implementação da DMIF II em Portugal
Slide 1: Introduction
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The
slide has been updated to reflect additional countries where the survey has and
is currently being implemented. In addition to Denmark, France and Germany, the
results of which were presented in Beirut Lebanon, an additional 4 countries
have been added: UK, Finland, Austria and Portugal. Today’s presentation will
present the preliminary results for Portugal, and we are hoping that we will be
able to gather a few more responses to ensure a sufficient basis for comparison
amongst the countries.
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So
far, based on the preliminary results, we believe we are fairly confident that
we will have a basis for comparison amongst 5 of the 8 countries, we hope to
also be able to get enough respondents in Austria and the UK, though Romania
seems so far to be a tough case.
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While
the previous presentation of the results in Denmark, France and Germany also
included a comparison to the member organisations of BETTER FINANCE responses
to the survey, this will not be included in the preliminary results at this
point in time, but will be included in the final results, which we are aiming
to disseminate by the end of the year. We have to exert a big thank you to DSW
and Christiane, who in fact developed the first study and implemented it in
Germany, it is also the country that currently has the highest number of
respondents.
Slide 2: Number of
respondents
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As
we are still awaiting and hoping for a surge in respondents in both UK and
Austria, these have been left out. Germany has 448 respondents, Denmark and
France both have 92 respondents, Portugal so far have 52 respondents and
Finland has an impressive 261 respondents.
Slide 3: Implementation in Portugal
Law
nº. 35/2018, of July 20, transposes the MiFID II into the Portuguese law, that
entry into force on August 1st, 2018.
The PRIIPS regulation was implemented in January, 1st, 2018, and is
applied directly in Portugal. Doesn’t exist any Portuguese legislative
framework that implements these European standards and allows the NCA (CMVM) to
approve regulations.
Slide 4: Overall assessment
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here
we can see that Portugal is the most satisfied so far
Slide 5: Areas where
there are room for improvement.
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For
those present in Beirut, we presented the ranking of each of the countries
included, here you can see that but now also including Portugal.
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Interesting
is that tradability of securities is in fact not listed by any respondent in
Portugal.
Slide 6: Continuation
of last slide
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for
this presentation we also present the weighted average of the responses of
Denmark, France, Germany and Portugal. This is multiple choice question, here
we can see the percentage of the respondents, where the difference in number of
respondents is taken into account.
Slide 7: Information
on costs
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Here
we see that Portugal has a higher assessment than Germany, but lower than both
Denmark and France.
Slide 8: Information
on Performance
- Here we see that Portugal, again, places itself between Germany, more
negative, and France and Denmark, more positive.
Slide 9: KID
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Here
we can see that Portugal is in the middle when it comes to satisfaction level.
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The
circle shows the collective results for Denmark, Portugal, Germany and France
Slide 10: Interest in
newly available information
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Here
we can see what percentage of the surveyed want information on the different
proposed areas
Slide 11: Portugal
case – sum up
Our members positively
evaluate some reforms that result from MiFID, such us the obligation of
telephone conversations and electronic communications that may result in
transactions having to be recorded and made available to customers.
In other hand, many
criticisms arose for the implementation of the LEI code and the information
about risks and costs, even if they agree that in this area there has been some
improvements.
The main problem that
seems to concern our members is the clarity/intelligibility of the information
provided by the issuers and FIs, namely about costs (including ex-ante costs) and risks.
The amount of
information is another issue that arose some criticism. Our members get
frustrated with the amount of information which doesn’t directly relate to
their needs and interests.
Our members feel that
the majority of KIDs have become overwhelming, when the investors are only
interested in obtain true, transparent, and complete information about costs,
risks, and performance.
