The European MiFID Template (EMT) has been used to deliver target market data and costs and charges data from fund groups to distributors since January 2018. The EMT was developed to standardise the categorisation of the target market and to enable distributors to search for funds based on the providers’ generic target market, as required by MiFID II.
The target market is divided into five client categories and the distribution strategy, with the options for UK distribution as follows:
- Investor type: Retail, Professional, Eligible counterparty
- Knowledge and/or experience: Basic, Informed, Advanced
- Ability to bear loss: No capital loss, Limited capital loss, No capital guarantee, Loss beyond capital
- Risk tolerance: The PRIIPs KID SRI, UCITS KIID SRRI or High/Medium/Low for products with no KIID or KID
- Client objectives and needs: Preservation, Growth, Income, Hedging, Option or leveraged return, Other, Specific investment need (eg Sharia, ESG, Green), together with the investment time horizon
- Distribution strategy: Execution only, Non-advised with appropriateness test, With investment advice, Portfolio management
A second version of the EMT was adopted at the beginning of 2019. The new version was created with input from the structured products industry as additional fields in the new EMT were specified by them.
The European Working Group behind the EMT has been transformed from an affiliation of fund groups and trade bodies around Europe into the more formal and structured FinDatEx. Version 3 (V3) was released on 10th December 2019 for industry use as of 1st January 2020.
Key files have been made available by FinDatEx (findatex.eu):
Below are some of the key features of EMT V3.
New date fields
There are extra date fields throughout the template – file generation date, reference date for general data, target market reference date, ex ante costs date and ex post costs start and end dates. While care should be taken to ensure the right dates relate to the right sections, these multiple date fields help make it clear if only part of the template is being updated.
Annualised ongoing costs
All ongoing costs should be annualised, even if the reporting period is shorter, for example, if a fund or share class has only been in existence for three months.
Instead of using “99.99” to indicate that a fund does not have a performance fee, a Y/N field has been added to the General Instrument information section to show this.
Target market fields
Some of the target market fields have been renamed to make it clear that they should be seen from an investor’s standpoint, not the fund’s. Showing that a UCITS fund is compatible with investors who are prepared to lose more than their original investment does not imply that the fund could lose more than 100%.
The target market Investor Type, Knowledge & Experience and Client Ability to Bear Losses sections use hierarchical logic. For example, a fund that is compatible with clients who cannot bear any capital loss is also automatically compatible with clients who can bear to lose some, all or more than their original investment. FE's EMT validation rules will take this logic into account.
A field has been added to the Client Objectives & Needs section to show if the product is compatible with clients who have an ESG preference. No further guidance will be provided and no further detail is required beyond Y/N/Neutral, so distributors will then need to investigate further to see if a fund’s ESG policies meet the specific needs of a potential investor.
Frequency of updates
In most countries (notably excluding the Nordic countries), monthly data accuracy is expected to be enough, but the template must be updated in the event of any material change.
Who does it impact?
Those who produce EMT data such as fund managers, administrators and third-party providers will need to ensure they are ready and able to switch-over to EMT V3 by 10 December 2020.
FE fundinfo suggests that groups continue to provide EMT V1 for the duration of the dual-running period, even if you are able to provide V3, as some fund distributors will not be able to accept the new template until a later date in 2020.
Groups can also validate their regulatory data files through our Data Partner Portal prior to sending through their V3 template.
As a fund distributor currently taking regulatory data feeds from FE fundinfo, EMT V3 files will be made available throughout 2020 (in addition to EMT V1 files).
A sample file will be made available to platforms and will be included as part of the specification document/user guide. Details of this will be made available upon request. Please contact your usual FE fundinfo relationship manager for more information.
How we can help
FE fundinfo validates, disseminates and delivers EMT data through our regulatory data solutions and feeds. If you do not have an existing file data arrangement in place with FE fundinfo and in need of a regulatory data feed, contact us now.