Knowledge Base
Implement personal transaction regulations in accordance with ethical guidelines
What is the typical timeframe for receiving an approval response for a personal transaction?
The approval or refusal response is generally provided within 24 to 48 hours. This timeframe allows for adequate verification while ensuring that the transaction can be executed within a reasonable period.
What is the obligation of employees regarding the reporting of personal transactions?
Employees must report without delay any personal transaction carried out, either through direct declaration or automated transmission from the account-holding institutions. This obligation ensures transparency and traceability of operations.
What is the definition of a personal transaction according to Article 29 of Delegated Regulation 2017/565?
Article 29 defines a personal transaction as a transaction in a financial instrument carried out by or on behalf of a 'relevant person' acting outside the scope of their professional activity. This includes transactions on own account, for related persons, or where there is a direct or indirect material interest.
Categorize items by dragging them to the appropriate zones
Items to categorize:
Exempt transactions
Prohibited transactions
Transactions requiring enhanced approval
Personal transactions can be classified according to their nature and the applicable restrictions. For example, transactions in diversified UCITS units benefit from specific exemptions, while short selling is generally prohibited.
Short selling is generally permitted in the context of personal transactions.
Short selling is generally prohibited under the additional restrictions governing authorised transactions. This is intended to prevent market abuse and conflicts of interest.
Minimum holding period for personal transactions
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Minimum holding periods are generally 30 to 60 days. This is intended to prevent short-term speculative trading and ensure market stability.
Exemptions for certain transactions that do not present a conflict risk are provided for by Article 29 of the Delegated Regulation.
Article 29 provides exemptions for certain transactions, such as those carried out under a discretionary management mandate without the employee's influence, or in diversified UCITS units. These exemptions are designed not to unnecessarily hinder risk-free operations.
According to Article 16(2) of the MiFID II directive, who is subject to personal transaction rules?
Article 16(2) of the MiFID II directive requires investment firms to establish rules for personal transactions of directors, employees and tied agents. These rules apply to all persons who may influence or be influenced by the firm's financial operations.