Implement conflicts of interest + inducements + product governance under MiFID II Articles 23 + 24(7)-(9) + 16(3) + Commission Delegated Directive (EU) 2017/593. Conflicts of Interest Article 23 + Commission Delegated Regulation 2017/565 Articles 33-35 - identify + prevent + manage + disclose conflicts including between firm and clients + between clients + between management body + research function + own account dealing + outside business interests. Inducements Article 24(7)-(9) - BAN for independent investment advice and portfolio management on receiving or paying any fees commissions monetary or non-monetary benefits from third parties + ban on retention even with disclosure. For non-independent advice and other services - quality enhancement test + reasonable demonstration that inducement does not impair duty to act in best interests of client + extensive disclosure. Research unbundling Article 13 Commission Delegated Directive 2017/593 (note 2024 Review reversed unbundling for SMEs + fixed income). Product Governance Article 16(3) + Article 24(2) + Articles 9-10 Commission Delegated Directive 2017/593 - target market identification + product testing + scenario analysis + distribution strategy + ongoing review + information flows manufacturer to distributor + non-compliance escalation. Payment for Order Flow (PFOF) ban under MiFID II Review 2024 for retail clients.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.