UPDATE. MiFID II PREPARED

Transcription

1 UPDATE MiFID II PREPARED 1

2 QUESTIONS, RULES & EXAMPLES What is my primary nationality? Lots of people have more than one nationality. For example, a participant might be born in Ireland, but moved to France as a child and is a national of both countries. It is also common for some people to be born in one country, but to later apply for citizenship in another country. There are some rules for deciding which nationality is a participant s primary nationality. Rules 1. If the participant has more than one nationality and one of them is an EEA country, but the other is not an EEA country (for example Australia or the U.S.), then the EEA country is considered to be the primary nationality for MiFID II. Examples 1. John was born in London in the United Kingdom. He moved to the U.S. to work in 2000 and has been working there ever since. He was recently granted U.S. Citizenship and holds a U.S. passport. Answer: John has two nationalities United Kingdom and the U.S. Because only the United Kingdom is in the EEA, that will be considered to be his primary nationality for MiFID II. His national identifier will be his UK Insurance number. 2. If the participant has more than one EU nationality, the one which is listed first alphabetically on the table in the Schedule below is considered to be the primary nationality. 2

3 QUESTIONS, RULES & EXAMPLES 2. Sofie was born in Milan but has Danish parents and has availed of her Danish nationality for work and other purposes. Which is her primary nationality? Answer: Sofie has two nationalities Denmark and Italy. Looking at the table in the Schedule below, Denmark (DK) comes before Italy (IT) in alphabetical order, so Denmark would be considered to be Sofie s primary nationality for MiFID II. Note: It is the two - letter country code which decides priority, not the name of the country. 4. Alexander has dual German and Finnish nationalities. Which is his primary nationality? Answer: In the table in the Schedule below, Finland (FI) looks like it comes before Germany (DE) in alphabetical order. But, it is important to check the two - letter country code not the name of the country. So Germany (DE) actually comes before Finland (FI) in the table. Therefore, Alexander s primary nationality for MiFID II is Germany. His national identifier will be. 3. Maria has dual Spanish and Portuguese nationalities. Which is her primary nationality? Answer: Looking at the table in the Schedule below, Portugal (PT) looks like it comes before Spain (ES) in alphabetical order. But, it is important to check the two - letter country code not the name of the country. So Spain (ES) actually comes before Portugal (PT) in the table. Therefore, Maria s primary nationality for MiFID II is Spain. Her national identifier will be her Tax identification number (Código de identificación fiscal). 3

4 QUESTIONS, RULES & EXAMPLES What is? is a special type of national identifier which is made up of 1) the two - letter country code, 2) date of birth, the first five letters of the participant s first name and 4) the first five letters of the participant s surname or family name. The rules for generating the are very complex. The good news is that participants do not need to worry about this because we at Global Shares have developed our IT system to do all the hard work. Once we know the participant s nationality, full, official name and date of birth, we can do the rest. What do participants need to do now? Participants should log in onto their Global Shares EquityGateway portal at [URL] as soon as possible, and definitely before 31 December When they log in, they will see a new task which they will have to complete. We have designed that task to gather all the information we need in order to comply with MiFID II. Once they have completed the task, we will do all the rest of the work. What is the new task? The new task has been designed by Global Shares to gather all the required information in as easy a way as possible. The process for completing the task is straightforward. Participants will see a copy of the table below. They simply choose their primary nationality and then complete no more than three fields. There will be clear explanations on the screen as well as links to lots of examples and guidance. Remember, participants should log in onto their Global Shares EquityGateway portal at [URL] as soon as possible, and definitely before 31 December 2017 in order to complete the task. Why do participants need to complete the task before 31 December 2017? MiFID II comes into force on 3 January We will need to receive their information a few days before that deadline so that we can process it. If they have not completed the task, they will not be able to buy shares, sell shares, transfer shares or exercise options using their Employee Share Account until they complete the task. So, the easiest thing to do is to log in onto their Global Shares EquityGateway portal at [URL] as soon as possible, and definitely before 31 December 2017 in order to complete the task. 4

5 SCHEDULE NATIONAL IDENTIFIERS Two Letter Code Country 1 st Priority Identifier 2 nd Priority Identifier 3 rd Priority Identifier AT Austria BE Belgium Belgian (Numéro de registre national Rijksregisternummer) BG Bulgaria Bulgarian Personal CY Cyprus CZ Czech Republic identification number (Rodné číslo) DE Germany DK EE ES Denmark Estonia Spain Personal identity code 10 digits alphanumerical: DDMMYYXXXX Estonian Personal Identification Code (Isikukood) Tax identification number (Código de identificación fiscal) FI Finland Personal identity code FR France GB United Kingdom UK Insurance number 5

6 SCHEDULE GR Greece 10 DSS digit investor share HR Croatia Personal Identification (OIB Osobni identifikacijiski broj) HU Hungary IE Ireland IS Iceland Personal Identity Code (Kennitala) IT Italy Fiscal Code (Codice fiscale) LI Liechtenstein LT Lithuania Personal Code (Asmens kodas) Identity Card LU Luxembourg LV Latvia Personal Code (Personas kods) MT Malta Identification NL Netherlands Identity Card NO Norway 11 digit personal ID (Foedselsnummer) PL Poland Identification (PESEL) Tax (Numer identyfikacji podatkowej) 6

7 SCHEDULE PT Portugal Tax (Número de Identificação Fiscal) RO Romania Identification (Cod Numeric Personal) SE Sweden Personal Identity SI Slovenia Personal Identification (EMŠO: Enotna Matična Številka Občana) SK Slovakia Personal (Rodné číslo) All Other Countries: 7