MiFID2 - Market in Financial Instruments Directive, second edition

The aim of the Market in Financial Instruments Directive (MiFID) is to harmonise European financial markets and improve their transparency by putting in place a regulatory regime applicable to investment services. The strengthening of this directive, MiFID2, has been applicable since 3 January 2018. MiFID2 provides you with greater transparency and protection in your investment decisions.

In concrete terms, at ING:

  • We will be paying increased attention to your investment experience during your transactions on financial instruments.
  • At the end of each investment consultation with your advisor, we will give you a report summarising the investment recommendations made on the basis of your personal situation and investor profile.
  • For certain more complex financial products, we will provide you with a standardised document (Key Information Document, or ‘KID’) enabling you to better understand the risks inherent in the proposed investment.
  • We will no longer receive trailer fees as part of discretionary portfolio management.
  • The rules on protecting your assets have been strengthened. For example, if you delegate the management of your share portfolio to us, we will alert you immediately if its value diminishes by more than 10 percent following fluctuations in the financial markets.

Your dedicated customer relationship manager will be happy to explain these changes, and see along with you how to open new doors for the financial management of your portfolio. 

Find out about our investmet solutions.

Are you a business? Get detailed information on MiFID2.

MiFID2 in practice 

MiFID 2 regulations state that we have to classify our clients into three categories:

  • Retail Clients, 
  • Professional Clients,
  • Eligible Counterparties.

Depending on this classification, there is a higher or lower degree of disclosure and protection, with Professional Clients and Eligible Counterparties being deemed to have the experience, knowledge and expertise to enable them to take their own investment decisions and adequately assess the risks involved.

The client is informed of his/her classification when his/her account is opened. He/she has the option of asking the Bank for a different classification if the legal conditions are met.

Since 3 January 2018, we have been obliged to declare to the regulators all the transactions executed by our clients in their securities accounts. Each client as a unique identifier.

Legal entity clients must be identified by an international identifier (Legal Entities Identifier – LEI) in order to be able to carry out transactions on the financial markets.

In practice, this means that, to be able to carry out transactions in your securities account with ING or any other European institution, you must have notified your LEI to your bank.

How do you obtain an LEI for your legal entity?

If you do not yet have an LEI, you must get hold of one from a service provider. The list of these service providers is available at www.leiroc.org (example of a service provider in Luxembourg: LuxCSD). The process for obtaining an identifier is straightforward and should only take a few minutes.

Note, though, that it may take several days or even weeks to obtain one.

How do you notify your LEI to ING Luxembourg SA? 

Send your LEI to the following email address: contactcenter@ing.lu.

Since 3 January 2018, we have been obliged to declare to the regulators all the transactions executed by our clients in their securities accounts. Each client as a unique identifier.

The identifier used for private individuals may vary depending on the client’s nationality. In most cases, ING Luxembourg is already in possession of this identifier. Here are a few examples:

  • Italian nationality: Italian tax number
  • Luxembourg nationality: Nationality+Last Name+First Name+Date of Birth
  • Belgian nationality: National register number.

Best order execution makes it possible to take sufficient measures to obtain the best possible result when the Bank executes a client’s orders, taking account of certain factors and criteria.

The execution policy of ING Luxembourg S.A. (‘ING’) applies both to Professional Clients and to Retail Clients for processing and executing orders concerning financial instruments.

 Top 5 execution venues and entities: Analysis & conclusions

Top 5 execution venues and entities: Figures

The objective of transparency in MiFID 2 is to enable you to more easily identify all the costs and charges in relation to your investments:-

• You will be provided with data showing all the direct and indirect costs associated with each stock market transaction (simulation before transmission). 

• You will receive, periodically, new reports showing all the fees associated with the financial instruments and services to which you subscribe (transaction fees, brokerage fees, account fees, management commissions, any remuneration received by the Bank from third parties in connection with your transactions, etc.).

• Such remuneration, commissions or non-monetary benefits paid or received by the bank in connection with an investment service shall be deemed to improve the quality of the service provided to the client.

Please consult our overview of costs and charges connected with financial instruments to gain a better understanding of the costs associated with transactions and holding financial products :

ING takes the view that no professional decision may be influenced by personal interests.

ING must take all reasonable measures to adequately identify, prevent and manage conflicts of interest which might undermine its clients’ interests. The Bank and all its employees must therefore take reasonable measures to avoid, as far as possible, such conflicts of interest or situations liable to generate them.

Examples of conflicts of interest :

- An employee would favour the Bank’s commercial policy by selling a in-house investment product to the detriment of a third-party fund without taking account of the client’s investor profile.

- Acceptance by ING employees of gifts or invitations to events could influence their behaviour by, for example, according preferential treatment to one or more clients.

ING has put in place an organisational structure including rules and responsibilities in the prevention and management of conflicts of interest. The Bank has also established a policy, procedures, mechanisms and processes making it possible to take all necessary and reasonable measures to prevent, identify, manage, report and control conflicts of interest.

Inducements are any kind of payment or non-monetary benefit received or paid by the Bank from or to any third party, or a person acting on behalf of a third party, in relation to the provision of an investment or ancillary service to clients such as non-independent advice or execution only. They are subject to conditions set out in MiFID 2.

Any payments or benefits received or paid by the Bank which enable or are necessary for the provision of investment or ancillary services and which are not capable of giving rise to conflicts with the Bank’s duty to act in accordance with its clients' best interests (e.g. custody costs, settlement and exchange fees) are proper fees and do not fall under the scope of the inducements’ MiFID 2 requirements.

When an inducement is paid or received in connection with the provision of an investment service or ancillary service to the client, the Bank will ensure that all the conditions set out in MiFID 2 are met at all times. The Bank accepts only inducements that are designed to enhance the quality of the relevant service to the client or qualified as “acceptable minor non-monetary benefits” within the meaning of MiFID 2 and do not impair compliance with its duty to act honestly, fairly and professionally in accordance with the best interest of its clients. The Bank does not keep nor pay any form of monetary inducements and does not accept any form of non-monetary inducements in relation to its discretionary management investment service, except minor non-monetary inducements in accordance with the principles enacted by the MiFID 2.

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