Would investment advisory mandates (i.e. investment manager provides recommendations regarding investment strategies to the investor, while the investor takes the investment decisions) be included in the required activities for asset managers (e.g. similar to discretionary mandates) or not applicable and fall under “Advisory services” as defined on p. 57 of the guidelines?
Welcome to the community @Claudio,
Apologies for the late reply.
The short answer is no, you would normally not need to include advisory mandates.
The slightly longer answer is that we require all discretionary mandates to be included and for this purpose we define discretionary mandates as:
If an asset manager/financial institution can make investment decisions or have been or is involved in designing the investment strategy, i.e. have had or has some influence over security selection and/or can vote for the securities in its portfolio, these assets shall be included in the target boundary. This requirement also applies to passive investment strategies and vehicles such as exchange traded funds (ETFs) that are following rules-based investment strategy where the asset manager has been able to influence the design of the strategy (e.g. “Smart Beta” products).