54580-22 20355 mifid 2 identifiers sales aid fact sheet p5… · title: 54580-22 20355 mifid 2...
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Reportable assets, at present, on FundsNetwork are Exchange TradedProducts (ETFs and ETCs) and Investment Trusts.
On the basis of this, you will be asked for an individual identifier,linked to the reportable nationality. This will consist of up to threeoptions, which are dependent on nationality.
The table below can be used to determine the National Identifierthat will be needed for a client or decision maker, depending on thenationalities they hold.
If the client or decision maker has UK Nationality, plus one or moreEuropean Economic Area (EEA) Nationality, they must provide the
highest priority identifier they hold (according to alphabeticalprecedence of the two character nationality code).
For example, we would need to provide a Greek National Identifierahead of an Icelandic National Identifier. But a client or decisionmaker who is a UK and Slovenian National would only need toprovide a National Insurance Number as the UK (GB) is higher inthe list according to alphabetical precedence.
Concatenated ID (CONCAT): We can derive an identifier from theclient’s first name, surname, nationality and date of birth.
There are further scenarios on the next page.
If your clients transact in reportable assets, we require all nationalities a client has for Anti-Money Launderingregulations. With MiFID II, we are now also required to provide a nationality identifier to the FinancialConduct Authority (FCA). Our system will identify, based on the nationalities that have been input,which one is reportable to the FCA.
NationalityCode (used foralphabeticalprecedence)
Country Name 1st Priority Identifier 2nd Priority Identifier 3rd Priority Identifier
AT Austria CONCAT
BE Belgium Belgian National Number CONCAT
BG Bulgaria Bulgarian Personal Number CONCAT
CY Cyprus National Passport number CONCAT
CZ Czech Republic National Identification Number Passport Number CONCAT
DE Germany CONCAT
DK Denmark Personal Identity Code CONCAT
EE Estonia EstonianPersonal IdentificationCode
ES Spain Tax Identification Number
FI Finland Personal Identity Code CONCAT
FR France CONCAT
GB United Kingdom UK National Insurance Number CONCAT
GR Greece 10 DSS-digit Investor Shares CONCAT
HR Croatia Personal Identification Number CONCAT
HU Hungary CONCAT
IE Ireland CONCAT
IS Iceland Personal Identity Code
IT Italy Fiscal Code
LI Liechtenstein National Passport Number National Identity Card Number CONCAT
LT Lithuania Personal Code National Passport Number CONCAT
LV Latvia Personal Code CONCAT
MT Malta National Identification Number National Passport Number
NL Netherlands National Passport Number National Identity Card Number CONCAT
NO Norway 11-digit Personal Identification CONCAT
PL Poland National Identification Number Tax Number
PT Portugal Tax Number National Passport Number CONCAT
RO Romania National Identification Number National Passport Number CONCAT
SE Sweden Personal Identity Number CONCAT
SI Slovenia Personal Identification Number CONCAT
SK Slovakia Personal Number National Passport Number CONCAT
All other non-EEAcountries
National Passport Number CONCAT
This document is for investment professionals only and should not be relied upon by private investors.
MiFID II:new information required for individual clients
Examples1. UK Nationality onlyIf the client or decision-maker is a UK National ONLY, then you needto ask them to provide their National Insurance Number. If the clienthas never been issued with a National Insurance Number, we willbe able to derive a reportable identifier using a CONCAT.
2. UK and French NationalityIn this example, France is above the UK in the table, therefore theidentifier we need to capture and report is specified for France. Francedoes not require a specific identifier and uses a concatenation derivedfrom the client’s name, surname, date of birth and nationality.Therefore no additional information is required for the client.
Please note: in this instance a National Insurance Number would stillbe required for Anti-Money Laundering regulations (AML), but not forMiFID II regulatory reporting.
3. UK and Portuguese NationalityIn this example, Portugal is below the UK in the table, therefore theidentifier we need to capture and report is specified for the UK,which is the National Insurance Number, unless the client has notbeen issued with one. It is not necessary to capture the Tax Numberspecified for Portugal.
4. UK and South African NationalityIn this case, the EEA Identifier takes precedent. Therefore the onlyidentifier that needs to be captured for this client is the UK NationalInsurance Number.
5. Norwegian and Chinese NationalityIf the client does not hold UK Nationality, then an EEA Nationalitywill take precedence over a non-EEA Nationality. In this example,we need to capture the identifier specified by Norway, which is an11 digit Personal Identification Number.
Issued by Financial Administration Services Limited, authorised andregulated by the Financial Conduct Authority. Fidelity, FidelityInternational, FundsNetwork™, their logos and F symbol aretrademarks of FIL Limited. UKM0717/20355/SSO/0118