Italy – CM EAM – Update 2021

Mar 8, 2021

Country Manuals Independent Portfolio Manager/Advisor (EAM) – 

BRP SA is glad to announce the publication of its COUNTRY MANUAL INDEPENDENT PORTFOLIO MANAGER/ADVISOR for the following jurisdiction:

ITALY OUT OF THE COMPANY’S COUNTRY OF ESTABLISHMENT (Def, RS & BT)

Regulatory Summary

Material changes
This document has been slightly reviewed to take account of an evolving interpretation of the applicable legal and regulatory framework.

Without prejudice to the foregoing, we confirm that there have not been any relevant regulatory changes to the documents since the last update.

The main changes are reflected as follows:

– Reporting activities – Actively and passively undertaking reporting activities (providing account/deposit information and statements as well as reports on managed account performance) during on-site meetings is now a ‘grey zone’. Moreover, the Company must in any case refrain from undertaking any other restricted activity (such as providing a client with investment advice).

Non-material changes
Certain comments have been considerably reworded (without introducing material changes) to reflect the new format of the document.

Behaviour Template
The answers in the BT have been aligned to those contained in the RS.

BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM EAM BT SHORT COMP” and “ITALY” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

Best regards,