About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

Regulatory Environment for Investment Research Facing Uncertainty, Substantive Study Says

Subscribe to our newsletter

Investment research provision in the US, Europe and the UK is facing more uncertainty as the market awaits significant changes to the regulatory landscape, according to a study of the current state of broker research pricing, supply and market share by Substantive Research.

According to Substantive, MiFID II’s implementation in 2018 increased the focus on the value and cost of research, and a steady decline in research pricing has followed since then, alongside brokers downsizing their analyst teams on both sides of the Atlantic. However, certain brokers have now bucked this trend and attracted stronger revenues and greater market share, rising significantly higher in Substantive Research’s top 20 broker league table by share of research payments.

The study showed US broker Jefferies moving up to third spot from seventh at the expense of UBS, with JP Morgan and Morgan Stanley retaining the No 1 and No 2 positions in the rankings. This, according to Substantive, “is a direct result of investing in hiring and retaining skilled research analysts at a time when the market in general saw a post-MiFID II price deflation and a move towards juniorisation of research.

“Although Jefferies’s analyst teams have shrunk somewhat post MiFID II, in proportionate terms, the net experience lost between 2019 – H1 2022 was 70% lower than the top ten providers, and 80% lower than their peers in the top five. What’s more, where Jefferies did lose experienced analysts, they replaced them with targeted, highly ranked analysts in order to maintain the quality of the research product.”

Substantive notes that change is imminent in the major jurisdictions setting policy around investment research. In the European arena, Substantive expects MiFID II’s research unbundling reforms to be softened, although it’s unclear to what extent or what impact that may have. In the EU, the imminent Listing Act is likely to include flexibility to rebundle research and execution under certain conditions. And the UK’s Investment Research Review will be completed in June 2023 and there has been reference to potential rebundling when it was launched this March.

In the US, meanwhile, the SEC’s no action relief that has been in place since 2018, which allowed cash research payments from Europe to the US to accommodate for MiFID II, will be allowed to expire and this has thrown the market into chaos, according to Substantive. US brokers do not know how they will be able to accept payments from European clients after July 3rd, 2023.

Previous Substantive Research data indicates that brokers are taking different approaches to these challenges. Some will allow their clients to pay through their European offices for research consumed globally, others are registering as Investment Advisors (or deciding to create the infrastructure for their existing RIA to charge for research) in order to continue to take cash payments for research.  But with time running out before the lapsing of the SEC’s ‘no-action’ letter, a Substantive Research study showed in February 2023 that the market still had not identified a consensus way forward for research providers.

Subscribe to our newsletter

Related content

WEBINAR

Recorded Webinar: Managing Non-Financial Misconduct Under SMCR

Non-financial misconduct – encompassing behaviours such as bullying, sexual harassment, and discrimination is a key focus of the Senior Managers and Certification Regime (SMCR). The Financial Conduct Authority (FCA) has underscored that such misconduct is not only unethical but also poses significant risks to a firm’s culture and operational integrity. Recognizing the profound impact on...

BLOG

SEC’s 2026 Examination Priorities – 10 Notable Changes

The U.S. Securities and Exchange Commission (SEC) has released its Examination Priorities for 2026, and while many supervisory themes continue from 2025, the tone and structure of the new document reflect a decisive pivot. After years of rapid organisational expansion and broadening remit, the Division of Examinations is now emphasising consistency, prioritisation and the effective...

EVENT

Eagle Alpha Alternative Data Conference, Spring, New York, hosted by A-Team Group

Now in its 9th year, the Eagle Alpha Alternative Data Conference managed by A-Team Group, is the premier content forum and networking event for investment firms and hedge funds.

GUIDE

The Reference Data Utility Handbook

The potential of a reference data utility model has been discussed for many years, and while early implementations failed to gain traction, the model has now come of age as financial institutions look for new data management models that can solve the challenges of operational cost reduction, improved data quality and regulatory compliance. The multi-tenanted...