DWS: MIFID II (EMT)

Zip container with all EMTs
Consolidated EMT file
Changelog

To all interested parties.


On this website you will find certain data that the asset management companies pertaining to DWS have delivered or will deliver to investment firms which engage in investment services under the Directive 2014/65/EU (Market in Financial Instruments directive – „MiFID II“)  and the Commission Delegated Regulation (EU) 2017/565 of 25 April 2016 supplementing MiFID II (together referred to as the “MiFID II Regulations”). The MiFID II Regulations come into effect as of January 3, 2018. In the following you will find some explanations which you may find useful.


What can I find on this website?


On this website (URL: https://dws.com/mifid_emt) you will find certain data in relation to investment funds managed by the asset management companies pertaining to DWS Group (“DWS”) that are distributed by investment firms regulated pursuant to the MiFID II Regulations. This data is provided in EMT format, this format as described in more detail here below. DWS makes this data available via the EMT on a voluntary basis only, i.e. without being under a regulatory obligation to do so, and without making any representation and/or warranty that the information contained therein is fit for any purpose.


What is the EMT?


The EMT (European MiFID Template) was jointly developed by manufacturers and distributors and their national associations across Europe providing a minimum set of data to fulfill the new requirements under the MiFID II Regulations. The data offered by DWS on this site uses the EMT standard version 1.1.

The data provided has been derived as follows:

Target Market

DWS identifies for each investment fund it manages a target market which specifies the type of client for whose needs, characteristics and objectives the investment fund is compatible. DWS uses the following list of target market criteria (“TM criteria”) and categories when describing the target market for an investment fund.

TM criteria

 Categories

Description

Type of Client
  • Retail Client
  • Professional Client
  • Eligible Counterparty
  • Category describes to which type of client the product is targeted. This specification is made according to the MiFID II client categorization which differentiates between three different client types.

Knowledge & Experience (K&E)
  • Basic
  • Informed/Average
  • Above Average
  • Specific Knowledge/Experience
  • Specifies the level of knowledge and/or experience (“K/E”) the target client should have about elements such as the relevant product type and product features in order to understand the risks involved in the transaction.
  • K/E will be assessed via  a client exploration (to assess whether the needed level of K/E is given) to be performed by the distributor

Ability to bear losses
  • Investor can tolerate no or minor losses
  • Investor can tolerate losses (up to the total invested amount)
  • Investor can tolerate losses (exceeding the total invested amount)
  • Losses target clients are able and willing to afford
  • Most of DWS investment funds will be classified with: “Investor can tolerate losses (up to the total invested amount)”

Risk Indicator
  • Risk Indicator: UCITS SRRI / PRIIPs SRI
  • The UCITS SRRI (“Systematic Risk and Reward Indicator) and/or PRIIPs SRI (“Summary Risk Indicator”) (level 1-7 with 7 being the highest risk level) can be used to categorize the risk / reward profile of a product.

Client’s objectives & needs
  • Specific Retirement Scheme
  • Capital Accumulation
  • Participate intensively in market fluctuations
  • Hedging
  • The first 4 categories can be attributed to the Client’s objectives while the category “Special Product Features” is a category of the criterion “Special needs”
  • In some cases the EMT uses other categories, e.g. instead of “Capital Accumulation” it will be differentiated between “preservation”, “growth” and “income”
  • Special Product features (“green investment”, “ethical investment”, etc.)
  • Differentiation into “Special Product Features” (“green investment”, “ethical investment”, etc.) or “other”

Investment Horizon

  • Short-term: < 3 years
  • Mid-term: 3-5 years
  • Long-term: > 5 years
  • Equals the number of years the investment should be held (the minimum holding period recommended by the manufacturer)
  • In EMT: additional option “Very Short Term < 1 year”

Distribution Strategy

Topic

Categories

Description

Distribution Strategy
  • Execution Only
  • Non-advised (execution based on appropriateness test)
  • Investment Advice
  • Recommendation of the distribution channel given by the manufacturer to the distributor
  • In EMT: additional distribution strategy of “Portfolio Management”

Cost Disclosure

MiFID II Cost Disclosure requirements aim at increasing cost transparency for investors on a quantitative as well as on a qualitative level. According to the relevant MiFID II requirement (Article 24 (4) (c) MiFID II ) investment firms have to disclose all relevant costs to the client; those relevant to the service and those relevant to the product. They have to be aggregated and provided ex-ante (i.e. before the client purchases a product) as well as ex-post, as the case may be, during the lifetime of the investment on at least a yearly basis.

DWS is going to provide following cost components as required by MiFID II.

Provided costs

Ex ante data

  • One-off cost Financial Instrument entry cost
  • One-off cost Financial Instrument entry cost Acquired
  • One-off costs Financial Instrument Maximum exit cost
  • One-off costs Financial Instrument exit cost Acquired
  • One-off costs Financial Instrument Typical exit cost
  • Financial Instrument Ongoing costs
  • Financial Instrument Distribution fee
  • Financial Instrument Management fee
  • Financial Instrument Transaction costs
  • Financial Instrument Incidental costs

Ex post data

  • Financial Instrument Ongoing costs
  • Financial Instrument Management fee
  • Financial Instrument Distribution fee
  • Financial Instrument Transaction costs
  • Financial Instrument Incidental costs
  • Beginning of calculation period
  • End of calculation period

What is the intended use for this data?


Under MiFID II, investment firms are required to identify or review and refine, as the case may be, the target market for each financial instrument they distribute. This means that they have to specify the type(s) of client for whose needs, characteristics and objectives the financial instrument is compatible. Further, MiFID II introduces new cost disclosure requirements which aim at increasing cost transparency for investors on a quantitative as well as on a qualitative level. Accordingly, investment firms have to disclose all relevant costs to the client; i.e. those relevant to the investment service and those relevant to the product.

DWS supports this process by delivering relevant data related to the target market and the costs of the relevant products in scope managed by it via the EMT to the investment firms to enable them to make their own assessment and analysis from the perspective of the distributing investment firm and eventually fulfil their new legal obligations.


How can I find a certain product?


The ZIP archive containing the data of all the different funds is available at the top of the page.

Files for specific funds can be found on the search site: Search

Files for individual funds can also be found in the ZIP archive containing the data of all the different funds mentioned above. With a click on the right mouse key you can start the download (“Save target as …”). Please specify a directory of your choice. Windows Explorer generally supports the ZIP format. After the download you can unzip the archive files. After that you have access to the single data files.

You can identify each fund and share class with the help of the ISIN that is part of each file name. Please note that the file names can be quite long (appr. 60 symbols). Accordingly problems can arise under Windows due to complex directory structures. A maximum of 255 symbols for file and directory names are allowed. The easiest way to search is to activate the search function via pressing “CTRL F”. A search data entry field will appear in the upper part of your screen where you can then enter the fund ISIN.

CIO View