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Free Trial Policy

Spread Research is committed to being fully compliant with the new MiFID II regulation, entering into force as of 3 January 2018.

This compliance applies even before we engage in a contractual relationship : in the context of MiFID II’s entry into force, several EU members’ financial authorities (in particular the FCA and the AMF) have detailed their views as to how Research Free Trials should be handled in compliance with the new regulation.

As per FCA’s PS 17/14 of July 2017 « Markets in Financial Instruments Directive II Implementation – Policy Statement II », with respect to section 2.3A.19 R of Annex F (« Amendments to the Conduct of Business sourcebook (COBS) »), an acceptable minor non-monetary benefit is one which (…) consists of (…) research that is received so that the firm may evaluate the research provider’s research service, provided that:

it is received during a trial period that lasts no longer than three months; no monetary or non-monetary consideration is due (whether during the trial period, before or after) to the research provider for providing the research during the trial period; the trial period is not commenced with the research provider within 12 months from the termination of an arrangement for the provision of research (including any previous trial period) with the research provider; and the firm makes and retains a record of the dates of any trial period accepted under this rule, as well as a record of how the conditions in (i) to (iii) were satisfied for each such trial period. »

AMF’s view is similar in essence to the above (see details in section 3.8 of the « Guide Financement de la recherche par les prestataires de services d’investissement dans le cadre de MiFID II », July 2017).

If your home regulator is not FCA or AMF, please refer to their websites for further guidance, as the case may be.

Our Free Trial period, that typically lasts for 2 weeks max for an individual prospect, provides you with access to our daily emails (push mode), our research platform (pull mode) and, if requested, one conference call meeting with one or several of our analysts.