Regulatory Alerts2013-06-19
Circular 3/2013 by the CNMV on information obligations for investment service clients regarding the assessment of financial instrument suitability and appropriateness (Amended by Circular 1/2014)
The Spanish National Securities Market Commission (CNMV) issued Circular 3/2013 to implement mandatory modifications to the Securities Market Law regarding client information obligations for investment services. The Circular mandates that entities provide written descriptions aligning investment recommendations with client suitability assessments, and requires specific handwritten warnings and signatures when appropriateness cannot be determined or when products are deemed unsuitable. Additionally, it establishes strict requirements for maintaining an updated, tamper-proof register of clients and unsuitable products, while outlining compliance procedures for electronic and telephone service delivery.
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