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European Federation of Financial Advisers and Financial Intermediaries (FECIF)

We think that the object, extent and all the definitions are appropriate and sufficiently clear.
We think that Title II of the guidelines is sufficiently clear and that all the criteria that are mentioned are appropriate and thus do not need to be removed.
We think that Title III is clear and sufficiently appropriate. We also think that the organisational and operative structure of investment firms is adequate and transparent and can contribute to demonstrate its effective and prudential management.
We think that Title IV is clear and appropriate as well as sections about conflict of interests and reporting procedures, although they seem to be difficult to manage.
We think that Title V is sufficiently clear and appropriate.
We think that Title VI is sufficiently clear and appropriate. It is fundamental that investment firms adopt effective recovery and management of business continuity plans that can assure its operativity while limiting losses in case of serious distress.
We think that Title VII is sufficiently clear and appropriate. It is important that strategies, policies and procedures are communicated to all the investment firm’s staff members, with their specific responsibilities and duties.
Paul Stanfield