COBS Flashcards
COBS apply to
Directly to firms conducting designated investment business or conducting long term insurance business
Electronic media
Website;
evidence of appropriate method Consent Info up to date Notified of website address electronically Accessible
Recordings
Kept 5 years - receiving, executing, arranging for client order
Durable medium
Unchanged reproduction of info stored
e.g.
paper
Floppy disc
Hard drive
Inducements
Reduce conflicts of interest
MIFID with regard to inducements
Firm not accept other than client a fee, commission or non- monetary benefit
unless
Fee enhance service
Doesn’t affect best interest of customer
Fee disclosed before providing service
prohibition does not apply to minor non monetary benefits
Non MIFID with regard to inducement
Disclosure required for personal recommendations for packaged products
Not required if minor non - monetary benefit
Inducements and Research
Firm apply charge for research
Pay via - direct payments, payment account controlled by firm
Research Payment account
disclose budget and costs for third party research
Regularly assess quality and effectiveness research provided
Reliance on others
MIFID - rely on info given by other MIFID firms
Non MIFID -
info in writing
third party independent
third party competent