The FSA has submitted its arguments for the retention of the IFA label, initial disclosure document and payment menu under Mifid to the European Commission.
Last week, the FSA forwarded to the Treasury its Article 4 notifications justifying why a number of national requirements go beyond the requirements of Mifid and need to be retained.
The FSA says it is unsure if the rules on independent, whole-of-market and multi-tie branding will be deemed as additional requirements but has included them in its submission.
It says the targeted disclosure documents and the brandings introduced by depolarisation are needed to help clients understand advisers’ status and the basis of their remuneration.
The EC will now examine the additional requirements submitted by each member state and correspond when it feels a requirement should be scrapped, rather than rubber-stamping every extra rule.
An FSA spokesman says: “We believe consumers rely on advice to a much greater extent in the UK retail investment market than do consumers in other member states.”
An EC spokeswoman says: “The considerable number of Article 4 notifications will be looked at over coming months on a case-by-case basis but we will not comment on specific additional requirements.”