SI DICX - Costs and inducements

MIFID II demands to preside over both eligibility and governance of subsidies, beyond the various commitments for ex-ante and ex-post disclosure.

SiGrade has achieved a new product, structured in three different modules, all capable of respective full cooperation, but contemporarily, depending on the particolar requirements of the Bank, allows an evenctual independent configuration, integrated with other applications of the Institute.


  • Enhancement Test
    This is a full modular, automatic and Bank-customizable process, and checks the eligibility of subsidies.
    It analyzes the codification of subsidy in order to separate the pecuniary subsidies from non-pecuniary ones, and, as a consequence, handle their treatment.
    It checks the possibility to perceive bonus based on both investment plan and analysis of quality parameters that can condition the passing of the test.
    At the end of the verification process, the acceptable subsidy is registered keeping track of the background that allowed validation conditions.
    Costi ed incentivi ex-ante 
    The system gathers information in relation with costs and bonus, where perceived, related to a single product offered together with information about result and date of the eligibility test.
    All the acquired data, including enhancement test, are at disposal of any consumer who ask about (online and/or postponed).


  • Costs and inducements ex-post
    Our application captures and elaborates costs and inducementss essentially paid and recognized by the various Manufacturers on the products that have been negotiated and contributes to the Bank report systems.
    Those Manufacturers that foresee a transmission channel instead of the Back Office systems, can opt for direct feed.
    A process of this application is finalized to the allocation of various gross values between the Bank subscribers, when the Manufacturer doesn’t know the correct subdivision. (ex. Government Securities/Bonds and Certificates drawn by issuer Authorities).
    Any kind of information acquired, normalized and aggregated, is then historicized on a data-base, which is, such as for the ex-ante data, at disposal of the various consumers (ex. periodic reporting to customers).

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