Response to consultation on draft RTS on requirements for policies and procedures on conflicts of interest for issuers of ARTs under MiCAR
Q2: Do you think that other types of specific circumstances should be covered by Articles 2 and 3?
Article 3 1. a)
The management body of an issuer has an interest in the optimized profitability of the issuer. As long as the issuer may earn a substantial part of its profit from the management of the reserve assets, the management body will lead the issuer to higher-risk assets within the allowed parameters. This will lead to substantial risks to the reserve assets in a crash scenario.
Q5: Do you have any comments on the provisions proposed in Article 7 on the Remuneration procedures, policies and arrangements? If so, please explain your reasoning.
Article 7 a)
The management body of an issuer has an interest in the optimized profitability of the issuer. As long as the issuer may earn a substantial part of its profit from the management of the reserve assets, the management body will lead the issuer to higher-risk assets within the allowed parameters. This will lead to substantial risks to the reserve assets in a crash scenario.