NFU comments on the MIFID II guidelines
NFU welcomes the ESMA consultation on new guidelines for MIFID II to further harmonize its implementation. As only half of the EU member states have taken affirmative action to integrate the new regulations on national level the new guidelines have the possibility to provide much needed assistance. The NFU consultation reply draw particular attention to clarify the intrinsic biases of robo-advice, MIFID’s possible contribution to sustainability, and access to human advice.
It cannot be overlooked that also algorithms and technique behind robo-advice can be exposed to bias and prejudice. As data too can culminate into conscious or unconscious patterns of discrimination. Gender diversification in the sectors’ growing IT workforce, financial literacy among customers, and the availability and cost of human advice when robo-advice fails to suffice, are all factors that need special consideration as fintech develops.
The High Level Expert Group on Sustainable Finance and Juncker’s SOTEU speech addressed the need to better promote sustainable finance and contribute to ESG (Environmental, social and governance goals). Therefore, the guidelines on MIFID II and investment advice should reflect this instead of limiting the scope of cost-benefit assessments to financial profit. This in turn could contribute to increasing overall client satisfaction by counterbalancing reputational risks that come with certain investments.
OECD and Kvalitetsindex both argues that as robo-advice becomes more common customers will increasingly request human services. Customers, including millennials will continue to request human advice when making big or high-risk investments (see survey from Denmark). It should be ensured that human service and advice continues to be available on an equal and indiscriminate basis to all customers without limitations to the clients ability to pay for human interaction.
Concludingly, NFU believes that the MIFID II guidelines could enhance the quality of advice by combining the effects of human service and fintech. The guidelines could contribute to more sustainable finance by putting the customer at the center and with investment not being limited by financial dimensions of cost and benefit.