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Finance Update
On 15 May 2014, the European Parliament adopted the legislative proposal on the second Directive on Markets in Financial Instruments (MiFID II) and the Regulation on Markets in Financial Instruments (MiFIR). Together, MiFID II and MIFIR significantly enhance the requirements which govern in-scope investment firms, trading venues, data reporting providers and third party firms providing investment services or activities in the European Union (EU). MiFID II and MiFIR will be applicable in all member states, including the UK, from 3 January 2018. Building on rules already in place, MiFID II and MiFIR are designed to take account of developments in the trading environment since the enactment of the first MiFID in 2007 (MiFID I). In light of the of the financial crisis, the EU aims to improve the functioning of financial markets and increase efficiency, resilience and transparency.
MiFID II sets out:
- Conduct of business and organisational rules for investment firms;
- Authorization requirements for regulated markets;
- Regulatory reporting to avoid market abuse;
- Trade transparency obligations for financial instruments;
- Rules on the admission of financial instruments to trading.
On 23 June 2016, the UK voted to leave the EU. Once the UK government formally notifies the European Council that the UK wants to leave the EU, the two year period for the negotiation for exit under Article 50 of the Treaty of the European Union may commence. Uncertainty about the legislative impact of Brexit, including MiFID II, will continue until the exact terms of the exit negotiation are finalised and published.
On 24 June 2016, the FCA confirmed in a press release that EU law will remain applicable to UK firms until any changes are made, which is a matter for the UK government and Parliament. The FCA instructed UK firms to continue to abide by their obligations under UK law, including those derived from EU law. We will continue to monitor the situation and will update you of developments that provide industry some certainty. You can also visit our Brexit page here for more insights.
Next steps
The FCA is expected to publish a fourth Consultation Paper later in 2016. We will continue to monitor developments and update you as they arise. It is important that all investment firms are 'MiFID II ready' by 3 January 2018 and compliant with the enhanced regulatory regime. If you need particular advice on how the UK implementation of MiFID II will impact your business, please contact Michael McKee, Mark Dwyer (derivatives), Tony Katz and/or Ian Mason.
Summary of key changes
1. Markets
MiFID II creates a new category of trading venue called Organised Trading Facilities (OTFs). The rationale for creating OTFs was to counter the development of broker-crossing networks (BCNs) and other 'dark' trading which evade the pre-trade transparency requirements of MiFID I by allowing anonymous and non-referenced off market trades Over The Counter (OTC). MiFID II aims to close BCNs out of equity trading and drive all equity and OTC derivatives trading onto regulated trading venues, a move which follows the introduction of the EU Regulation on OTC Derivatives, Central Counterparties and Trade Repositories (EMIR).
MiFID II introduces new market microstructure rules for regulated trading venues including minimum tick sizes for equities and 'equity-like' financial instruments as well as permitting higher fees on market participants with a high ratio of cancelled to executed orders, impacting participants who typically engage in High-Frequency Trading (HFT). The rules on both pre and post-trade transparency will apply to a larger number of financial instruments including those with 'equity-like' characteristics.
Whilst the reforms are positive in terms of market stability, questions arise regarding the limitation of both liquidity and business flexibility and freedom. It is anticipated that increased transparency and market consolidation may come at the cost of reduced market liquidity given the reduced choice of trading venues and the trading of fewer bespoke financial instruments.
2. Reporting
MiFID II extends the scope of transaction reporting to financial instruments admitted to trading or traded on any trading venue (currently only those admitted to trading or traded on a regulated market (RM) needs to be reported). Position reporting and disclosure requirements of commodity derivatives, emissions allowances and emission allowances derivatives have also been introduced. Double reporting of the same information under MiFIR and EMIR will be avoided. Investment firms should consider updating their reporting system functionality and leverage existing EMIR reporting infrastructure to the greatest extent.
3. Corporate governance and conduct of business requirements
MiFID II seeks to address perceived weaknesses in corporate governance in the financial services sector which has 'been a contributory factor to the financial crisis', a view on which 'there is agreement among regulatory bodies at international level' (Recital 5, MiFID II).
MiFID II requires the management body (typically the board) of investment firms to define, approve and oversee:
- A policy as to services, activities, products and operations offered or provided in accordance with the risk tolerance of the firm, ensuring appropriate stress testing of services or products;
- A remuneration policy for persons involved in the provision of services to clients.
In particular, MiFID II requires management bodies to have access to good quality management information and be composed of members of 'sufficiently good repute'. MiFID II also builds on the 'client's best interests' provisions of MiFID I, requiring product manufacturers to maintain adequate review processes and to ensure that investment products are 'consistent with the needs' of identified target markets. It should be noted that MiFID II empowers regulators to ban specific products, services or practices where there are threats to investor protection, financial stability or the orderly functioning of markets.
MiFID II expands on existing conduct of business requirements for investment firms. Currently, firms merely have to take 'reasonable' steps to identify and manage conflicts of interest, but under MIFID II, firms will be required to take 'appropriate' steps to identify, prevent and manage conflicts of interest. Firms that hold themselves out as 'independent' will be prohibited from retaining any fees, commissions and monetary or non-monetary benefits received from third parties. These firms are required to establish a policy to ensure third party payments are allocated and transferred to clients. For UK advisory firms, this change will not be as significant given that the UK already banned firms from receiving commission for both independent and restricted advice (the UK's Retail Distribution Review [RDR]).
UK implementation process
Member states have until 3 July 2017 to implement MiFID II, with the implementing legislation applying from 3 January 2018. MiFIR is a directly applicable regulation and will therefore apply without implementing legislation from 3 January 2018. Work is well underway by the European Securities and Markets Authority (ESMA) to produce level 2 measures including regulatory technical standards and implementing technical standards. For example on 7 April 2016, the European Commission adopted the first level 2 measure under MiFID II, a Delegated Directive on investor protection. Articles from this Delegated Directive are addressed in this Alert under the discussion of CP16/29. The Delegated Directive will need UK implementing legislation to come into force. On 20 April 2016, the European Commission endorsed draft regulatory technical standards on non-equity transparency, the ancillary test and position limits provided that certain changes are made. Further level 2 measures will be forthcoming.
In March 2015, Her Majesty's Treasury (HM Treasury) consulted on the implementation of MiFID II. HM Treasury will produce a policy statement in due course before presenting an implementation Bill to Parliament. HM Treasury consulted on third-country regime, data reporting services, position limits for commodity derivatives and reporting, unauthorised persons, structured deposits, the power to remove board members and OTFs.
In December 2015, the FCA published its first Consultation Paper 15/43 on the implementation of MiFID II and MiFIR (CP15/43). The FCA consulted on new rules governing the secondary trading of financial instruments and the conduct of business and organisational requirements for investment firms.
In March 2016, the Prudential Regulation Authority (PRA) published its first Consultation Paper (CP9/16) on the implications for PRA regulated credit institutions and designated investment firms on the UK implementation of MiFID II. CP9/16 addressed passporting and algorithmic trading issues only. The PRA is expected to consult on the remainder of its proposals in due course.
On 29 July 2016, the FCA published its second Consultation Paper (CP16/19) on the UK implementation of MiFID II and MiFIR. CP16/19 addressed a number of issues including commodity derivatives and systems and controls requirements. The closing date for responses to CP16/19 is 28 October 2016. Please refer to our Finance Update for an overview of CP16/19. This article outline the key points of CP16/19 in more detail below.
On 29 September 2016, the FCA published its third Consultation Paper (CP16/29). CP 16/29 includes proposals on conduct of business issues as well as a range of issues not covered in the previous consultations. The closing date for responses to CP16/29 is 4 January 2017, except for responses to Chapter 16 - 'Supervision manual, authorisation and approved persons', which should reach the FCA by 31 October 2016. The key points of CP16/29 are also outlined below.
The FCA expects to publish a fourth Consultation Paper later in 2016. The FCA will publish its own Policy Statement covering all aspects of the FCA's implementation of MiFID II in the first half of 2017.
FCA's second Consultation Paper
1. Commodity derivatives
MiFID II will bring a significant change to commodity derivative markets in the UK by requiring the FCA to set position limits of commodity derivatives trading on UK trading venues. CP16/19 consults on a new section of the FCA's Market Conduct sourcebook, MAR 10, that will set out guidance and directions on the MiFID II Directive regime relating to position limits, position management and position reporting for commodity derivatives contracts. Position limits will be set in due course and position reporting will apply to both trading venues and investment firms. Unauthorised firms may need to apply for exemptions from reporting position limits and authorised firms will need to put in place systems for recording, controlling and reporting commodity derivative positions.
2. Supervision
The FCA proposes to update the FCA Handbook's Supervision Manual (SUP) in order to:
- Ensure that notifications of breaches and relevant information directed to the FCA are accurate and take into account MiFIR and non-Financial Services and Markets Act 2000 HM Treasury implementing regulation;
- Include a transitional provision in SUP to ensure transaction reporting obligations incurred from 2 January 2018 continue as such following the repeal of a MiFID I implementing regulation;
- Update application forms for investment firms seeking passporting permission to ensure information required by the MiFID II level 2 regulations is provided.
3. Prudential standards
Firms operating an OFT will be required to hold €730,000 of base own funds capital in line with the requirement of the EU Capital Requirements Directive IV. CP16/19 also proposes updating the Prudential Handbook in light of MiFID II's removal of the 'local' exemption from MiFID I and removing outdated references to MiFID I where the matters are now dealt with in the EU Capital Requirement Regulation.
4. Senior management arrangements, systems and controls
As stated above, MiFID II revises current requirements requiring firms to take all 'appropriate' steps to identify, prevent or manage conflicts of interest from arising as well as increasing reporting obligations for firms. CP16/19 proposes to incorporate these requirements in the FCA's Senior Management Arrangements, Systems and Controls sourcebook (SYSC). Updated conflict of interests rules will require investment firms to update their existing organisational and administrative arrangements, and particularly their approach to disclosure. Whilst the FCA notes that this should not necessitate a 'material change in firms' systems and controls', a higher degree of sophistication will be required by firms to recognise and prevent conflicts before they arise. The FCA also sets out its proposed approach of how the management body and organisational requirements will apply to branches of non-EU firms and firms exempt under Article 3 of the MiFID II Directive.
5. Remuneration requirements for sales staff
The FCA proposes to make changes to SYSC to implement the remuneration requirements for sales staff in MiFID II. Built on existing ESMA guidelines, the rules seek to ensure that sales staff are not incentivised to act in ways which are detrimental to the interests of clients. At this stage, the FCA is only proposing to apply MiFID II's remuneration standards for sales staff and advisers who work for:
- Common platform firms (which include MiFID investment firms but exclude collective portfolio management investment firms);
- Article 3 firms;
- Branches of third-country firms (but only where their activities are carried on from an establishment in the UK).
6. Client assets
CP16/19 provides for incremental changes to the FCA's Client Assets Sourcebook (CASS). Many of the changes introduced by MiFID II are already part of the FCA rules. MiFID II will be implemented in CASS through 'intelligent copy out' meaning closely using the MiFID II wording but adapted, where appropriate, to align with UK law and practice. The FCA proposes to maintain the single rulebook approach by implementing MiFID II for all designated investment businesses to ensure the same standards and investor protections apply.
CASS will also incorporate a more extensive prohibition against Title Transfer Collateral Arrangements (TTCAs) with retail clients. TTCAs transfer credit risk from the firm to clients by treating client assets or monies as collateral. Retail clients are less likely to have the resources or experience to understand this risk and therefore they will benefit from CASS protections in line with the FCA's consumer protection and integrity objectives. TTCAs for retail clients are already banned for contracts for difference, spreadbetting and rolling spot forex. They will now be banned in respect of all MiFID II financial instruments for retail clients.
7. Complaint handling
The FCA proposes to update the FCA's Dispute Resolution: Complaints sourcebook (DISP) with a new definition of 'MiFID Complaint' covering complaints that use the new MiFID II complaint handling requirements. MiFID II extends record keeping and reporting requirements for MiFID Complaints to professional clients and eligible counterparties. This may have cost implications to investment firms who will be required to update systems in order to reflect the enhanced compliant handling requirements.
In line with the requirements of MiFID II, the FCA also proposes to extend the jurisdiction of the Financial Ombudsman Service to complaints about sales and advice in relation to structured deposits. The FCA proposes an additional rule which will require branches of UK MiFID investment firms to adhere to the relevant Alternative Dispute Resolution entities in the relevant European Economic Area State in which they are established.
8. Whistleblowing
In CP16/19, the FCA notes that there are various pieces of EU legislation in respect of whistleblowing, including MiFID II. The FCA states that the differences in scope and application of the various whistleblowing provisions are too great to enable the creation of one set of provisions covering them all. Instead, the FCA proposes a new FCA Handbook chapter to act as a single 'home' for all the various whistleblowing requirements. The FCA would signpost all EU whistleblowing obligations not implemented in the Handbook.
9. Fees
In CP16/19, the FCA proposes rules on the initial and ongoing regulatory fees for firms that wish to apply to operate an OTF or vary their permission to do so, or to operate an MTF, and on the onboarding fee for firms that connect to the FCA's market data processor. MTFs are charged with the FCA's 'complex' authorisation application fee of £25,000, and they pay a two-tier periodic fee depending on whether they are supervised by a named 'fixed portfolio' supervisor or by a team of 'flexible portfolio' supervisors. The FCA proposes to charge these same fees for operators of OTFs.
FCA's third Consultation Paper
On 29 September 2016, the FCA published its third Consultation Paper (CP16/29) on implementing MiFID II and MiFIR. The key proposals in CP16/29 are highlighted below.
1. Conduct of business proposals
1.1. Inducements, including adviser charging
Articles 24(7) to (9) of MiFID II enhances the existing MiFID inducement rules. Independent advisers and portfolio managers will no longer be able to pay and, or receive monetary and non-monetary benefits from third parties, other than 'minor non-monetary benefits' and those designed to enhance the quality of the service to the client and which do not impair the firm's duty to act honestly, fairly and professionally and in the best interests of the client.
The MiFID II inducement requirements for firms undertaking portfolio management activities go beyond the existing MiFID I inducement rules and the FCA's rules in the Conduct of Business Sourcebook (COBS).
Existing inducement rules in COBS apply to both MiFID and non-MiFID business, including business relating to insurance-based investments. The circumstances where inducements may be paid or received in relation to most types of non-MiFID business are less prescriptive.
In CP16/29, the FCA proposes to apply the MiFID II inducement rules:
- For MiFID businesses (including equivalent third country firms and Article 3 firms) while keeping the existing (less prescriptive) rules in place for non-MiFID businesses, such as insurance-based investments, until the FCA implements the Insurance Distribution Directive
- For professional clients as well as retail clients.
The FCA also plans to extend MiFID II's inducement ban in relation to retail clients:
- To restricted advice as well as independent advice;
- To prohibit the acceptance of commission and benefits rather than their acceptance and rebating to retail clients;
- To broaden the adviser charging rules by applying the ban to the business of providing advice rather than only to inducements provided in relation to the provision of a particular recommendation to a client.
The FCA proposes to define 'minor non-monetary benefits' as benefits clearly disclosed, reasonable, proportionate, capable of enhancing the quality of the service to the client and of a scale or nature that does not impair the firms behaviour nor compliance with its obligations (see COBS2.3A.15 R). Examples include written material that is commissioned and paid for by a corporate issuer to promote a new issuance, participation in training events on the benefits or features of a specific financial instrument and hospitality of a reasonable and minimal value whilst at such training.
1.2. Inducements and research
Article 13(1) of an EU Commission delegated directive supplementing MiFID II with regard to safeguarding of financial instruments and funds belonging to clients, product governance obligations and the rules applicable to the provision or receipt of fees, commissions or any monetary or non-monetary benefits (MiFID II Delegated Directive) acknowledges that third party research is an important tool for investment firms. It allows investment firms providing portfolio management or other investment or ancillary services, to receive research from third parties in a way that does not contravene the inducements rules where the research is paid for by the investment firm out of its own resources or via a separate research payment account controlled by the firm which may be funded from clients.
In CP16/29, the FCA propose a new COBS section 2.3B which transposes Article 13 of the MiFID II Delegated Directive. It will also transpose (as guidance) certain recitals of the MiFID II Delegated Directive on how firms should operate a research payment account and collect charges. Firms that wish to use client funds to obtain client-specific research reports should pay close attention to these requirements in COBS 2.3B, in particular the requirements of oversight, audit and controls regarding any research payment account. Clients must agree to any charges on the account and arrangements must be put in place to remit any unused funds back to the relevant clients.
1.3. Client categorisation
MiFID II continues with the existing MiFID I client classifications - 'retail', 'professional' or, for some types of business, 'eligible counterparty'. MiFID II extends the new conduct of business requirements to business with eligible counterparties.
Recital 104 of MiFID II notes that the "financial crisis has shown limits in the ability of non-retail clients to appreciate the risk of their investments". Claims by Italian public authorities relating to derivatives mis-selling highlighted this particular risk. Responding to these concerns, MiFID II categorises local authorities as retail clients with the ability to opt-up to elective professional status where they meet the qualifying criteria. However, MiFID II gives member states the discretion to adopt specific alternative or additional criteria for the assessment of the expertise and knowledge of local authorities requesting to be treated as elective professional clients.
The FCA proposes to exercise this discretion by introducing a requirement for investment firms to apply a qualitative test, a quantitative test and procedural requirements when opting-up local authority clients to professional client status. Investment firms that do business (MiFID business and non-MiFID scope business) with local authorities should reconsider their clients in light of these tests and procedural requirements. In summary, this requires a firm to undertake an assessment of the expertise, experience and knowledge of the local authority client and assess whether the client has either carried out a certain number of significant transactions within the previous four quarters or has worked in the financial sector for at least one year in a professional position.
Firms will also need to re-categorise their eligible counterparty clients who have been opted-up from elective professional client status. The differences in the way the COBS requirements apply to different client categories means firms should review the broader impact of this change on their business.
1.4. Disclosure requirements
MiFID II strengthens regulatory protections available to professional clients and eligible counterparties. Existing disclosure rules require firms to produce "fair, clear and not misleading information" in a comprehensible format and provide general and specific information about the firm, including its financial instruments, proposed strategies as well as its costs, safeguarding of client assets and reporting.
The FCA proposes to amend COBS in-line with the provisions in MiFID II and the MIFID II Delegated Directive. These changes will:
- Require firms to communicate with eligible counterparties in a way that is fair, clear and not misleading, taking into account the nature of the eligible counterparty and its business;
- Introduce more prescriptive rules on disclosures such as the font size of text identifying relevant risks, the consistency of the language used and the keeping information up-to-date;
- Require the disclosure of appropriate information to clients with regard to the investment firm and its services, the financial instruments and proposed investment strategies, execution venues and all costs and related charges (see new COBS 2.2A);
- Require information to be provided in a comprehensible form in such a manner that clients are reasonably able to understand the nature and risks (see new COBS 2.2A.5 R);
- Require a prescribed general list of information to be disclosed to clients (see new COBS 6.1-A);
- Require additional disclosures in respect of safeguarding client instruments and funds as well as information about costs and associated charges.
The new disclosure requirements are primarily applicable to firms doing MiFID business.
1.5. Independence
Current FCA rules on independence were introduced by the RDR and designed to ensure that independent advice is genuinely free from bias towards particular products. Currently, the rules apply firms making personal recommendations to retail clients in the UK on retail investment products (RIPs) - these include both MiFID (eg structured products) and non-MiFID investment products (eg insurance-based investments and personal pensions).
MiFID II introduces a EU-wide standard for "independent advice" which is broadly similar to current FCA rules. Firms providing independent advice will have to "assess a sufficient range of financial instruments available on the market which must be sufficiently diverse with regard to their type and issuers or product providers to ensure that the client's investment objectives can be suitably met". The FCA states that it intends to implement the MiFID II standards to all RIPs for UK retail clients. Rules in the MiFID II Delegated Directive in relation to the robustness of a firm's product selection process, will also be applied to non-MiFID II business. For professional clients and non-UK retail clients, the FCA will only apply the MiFID independence standard on MiFID financial instruments and structured deposits.
Given the already high standards required as a result of the RDR, the proposed changes will not have significant implications for investment firms. Some firms may need to consider MiFID II's organisational requirements, particularly in relation to MiFID II's prohibition on individual advisers providing both independent and non-independent advice.
1.6. Suitability
The existing requirements on suitability are set out in COBS 9 and apply to firms advising on, or managing portfolios in relation to, non-MiFID products as well as MiFID products. The current provisions will remain in place and will only apply to non-MiFID products.
Rules transposing the MiFID II suitability requirements will be set out in a new COBS 9A. The new rules include more specific requirements to ensure suitability of personal recommendations such as the obligation to ensure information about the client is up-to-date where the firm is providing ongoing advice or a discretionary management service. Additionally, the rules clarify that where advice or a discretionary management service is provided wholly or partly through an automated system, the firm remains responsible for the suitability assessment. Responsibility is not diminished by use of an automated system. In light of these rules, firms should consider their policies and procedures in respect of their clients and may need to establish more regular channels of obtaining client information. Firms should also consider any automated systems and satisfy themselves that system-generated advice or services are continuingly suitable for client needs.
1.7. Appropriateness
Investment firms, when considering distributing a product without personal advice, are required to assess whether the product sale is either 'non-complex' or 'complex'. Firms must then carry out an appropriateness test for all complex products and products deemed complex (such products cannot be sold execution-only). The appropriateness test requires the assessment of a client's knowledge and experience to determine whether the particular product or service is appropriate to the client.
Currently, the appropriateness requirements are set out in COBS 10 and apply to firms carrying on MiFID business. The current rules will continue to apply to both MiFID and non-MiFID business.
MiFID II permits firms to provide a limited range of investment services (execution or reception and transmission of orders) to a client without having to assess the appropriateness of the investment product for the client as long as certain conditions are met including that the product is 'non-complex':
- Does not contain a clause, condition or trigger that could fundamentally alter the nature or risk of the investment or pay out profile;
- Does not include exit charges that have the effect of marking the investment illiquid even though the client may have frequent opportunity to dispose, redeem or realize the product.
The FCA will also include in COBS 10:
- A rule that where a bundle of services or products is envisaged, the firm must consider whether the overall bundled package is appropriate;
- A specific requirement for firms to keep records of appropriateness assessments, including, where a warning was given to a client, whether the client decided to go ahead despite the warning and whether the firm accepted the client's request to go ahead with the transaction.
Firms will need to carry out the appropriateness test for a wider range of products than at present. When offering bundled products and services, firms will need to consider the appropriateness of the overall bundle. They will also need to record the results of a test, including, when a warning has been given but the client still wishes to proceed with the transaction, and whether they decided to carry out the client's request.
1.8. Dealing and managing
MiFID II enhances the MiFID I best execution requirements. Best execution rules are designed to increase transparency of order execution and order routing decisions and to facilitate better scrutiny of performance by clients.
The FCA proposes to amend COBS 11.2 by transposing the new MiFID II standards into a Dealing and Managing chapter as COBS 11.2A. Certain recitals of MiFID II will also be drafted in COBS as guidance. For example, recitals [100] and [108] clarify that firms may select a single venue for execution of client orders only where they can show that the venue consistently delivers the best possible results, which they reasonably expect are as good as results expected from alternative execution venues. This selection must be supported by quality data that is either published or used as part of the firm's internal analysis. The FCA also proposes to extend the best execution rules to non-MiFID business (Article 3 firms and managers of collective investment undertakings) retaining certain exemptions and modifications.
Investment firms will need to update their existing execution arrangements, execution policies and monitoring procedures. Following the guidance, investment firms will also need to demonstrate reliance on data in exercising any trading venue decision-making.
1.9. Underwriting and placing
There are currently no specific FCA rules covering underwriting and placing activities. Article 38 of the MiFID II Delegated Regulation supplementing MiFID II as regards organisational requirements and operating conditions for investment firms (MiFID II Delegated Regulation) introduces new underwriting and placing provisions, linked to MiFID II's organisational and conduct rule requirements. These provisions require information to be disclosed and conflicts managed in respect to underwriting and placing. For example, effective management of conflicts of interest arising when firms engage in the placement of financial instruments issued by themselves (or an entity in the same group) to their own clients is now covered. In the FCA's view this is already be covered in SYSC 10.
However, the FCA proposes to introduce a new chapter in COBS to implement the MiFID II rules on underwriting and placing. For example, COBS 11A.1.3 EU states that firms must, before accepting a mandate to manage an offering, have arrangements in place to inform the issuer client of:
- The various financing alternatives available;
- The timing and the process with regard to the corporate finance advice on pricing of the offer;
- Details of the targeted investors, to whom the firm intends to offer the financial instruments;
- Job titles and departments of the relevant persons involved in the provision of corporate finance advice on the price and allotment;
- Firm's arrangements to prevent or manage conflicts of interest that may arise where the firm places the relevant financial instruments with its investment clients or with its own proprietary book.
The new requirement in COBS 11A for underwriting and placing will require firms to establish specific measures to ensure compliance, if they do not already exist. The FCA notes that there will be 'resource implications, particularly around the new disclosure requirements'.
1.10. Investment research
The FCA proposes to incorporate the MiFID II investment research provisions into a single COBS chapter as well as adding guidance to clarify that the new rules will apply to both investment research and non-independent research. The current rules require firms to manage conflicts of interest in relation to the financial analysts involved in the production of investment research and other relevant persons whose responsibilities or business interests may conflict with the interests of the persons to whom research is disseminated.
The new rules put in place a number of requirements that require firms to put in place safeguards and arrangements on the production of investment research. For example, the following will need to be met:
- Financial analysts do not undertake personal trades in the investment to which the research relates;
- Physical separation exists between financial analysts who produce the investment research and others whose responsibilities may conflict with the interests of the recipients of the research putting in place appropriate information barriers;
- The firm itself as well as analysts do not accept any inducements from those with a material interest in the subject-matter of the research;
- The investment firms themselves, financial analysts, and other relevant persons involved in the production of the investment research do not promise issues favourable research coverage;
- Before dissemination of investment research issuers, relevant persons other than financial analysts, and any other persons, are not permitted to review a draft of the investment research for the purpose of verifying the accuracy of factual statements made in that research, or for any purpose other than verifying compliance with the firm legal obligations where the draft includes a recommendation or a target price.
1.11. Other conduct issues
The FCA proposes two additional changes to COBS:>
Firstly, the FCA proposes to require client agreements to be entered into for each investment service and ancillary service, not just for new clients. Firms already have to provide client agreements to retail clients. In the future they will also need to provide client agreements to professional clients and eligible counterparties.
The MiFID II Delegated Regulation goes into more detail of what should be included in a client agreement and includes:
- Detail of the services, and where relevant the nature and extend of the investment advice, to be provided;
- In the case of portfolio management services, the types of financial instruments that may be purchased and sold and the types of transactions that may be undertaken on behalf of the client, as well as any instruments or transactions that are prohibited;
- A description of the main features of any safeguarding services to be provided, including where applicable the role of the firm with respect to corporate actions relating to client instruments and the terms of which securities financing transactions involving client securities will generate a return for the client.
It also amends the record keeping requirement by reducing the retention period to 'at least the duration of the relationship with the client', instead of also having a requirement for records to be kept for at least five years. This will mean firms may decide for themselves whether, and if so, for how long, they wish to keep records after the relationship with a particular client has ended.
The FCA proposes to retail the current COBS 8 provisions for non-MiFID business and implement the more detailed MiFID II requirements for MiFID business (retail and professional clients and eligible counterparties). The FCA will introduce a new record keeping requirement for non-MiFID business other than pension transfers, pension conversions, pension opt-outs or Free Standing Additional Voluntary Contributions, for which records will continue to be required to be kept indefinitely. So for both MiFID and non-MiFID business, the requirement will be to keep records for at least the duration of the relationship with the client.
The FCA suggests that this is not an onerous requirement because, in practice, these agreements are already mostly in place. Updates to client agreements would be required when there is a change to a MiFID business provided to a client but not seemingly where, for example, a new product is offered under an existing service. Investment firms should review their client agreements in light of these changes noting especially the requirements in respect of professional clients, and update these agreements if required as well as firm procedures in respect to client agreements.
Secondly, the FCA proposes to engage in minor changes to the specialist regime for collective portfolio managers in COBS 18 by reordering and clarifying the provisions.
2. Other matters
2.1. Product governance
MiFID II imposes a number of product governance requirements on investment firms including the requirement to establish procedures to assess the risks and target market as well as monitor products on an ongoing basis to check whether they function as expected. Firms that manufacture products must design them to meet market needs, stress test them and provide relevant information to distributors. Investment firms that distribute products must gather information from manufacturers, provide information to assist manufacturers in conducting product reviews and work with other distributor firms involved in the sale. The new rules broadly replicate existing rules on product governance introduced by the RPPD.
The FCA intends to revise their approach to product governance from one of standard setting to one where the FCA is "willing to intervene more directly in the market if [we] identify situations where the potential for customer harm is not sufficiently reduced". The FCA assures readers that they will apply the rules "in an appropriate and proportionate way, taking into account the nature of the investment product, the investment service, and the target market for the product". The new rules will be introduced into a new sourcebook for Product Governance and Product Intervention (PROD). In light of these changes, firms that manufacture and/or distribute products should review policies and procedures, as well as systems and controls to ensure compliance with the enhanced product governance regime and regulatory scrutiny.
2.2. Knowledge and competence requirements
Article 25(1) of MiFID II requires firms engaged in MiFID business to ensure, and be able to demonstrate to the FCA, that individuals giving investment advice or information about financial instruments or investment or ancillary services to clients possess the necessary knowledge and competence to fulfil their investor protection obligations. ESMA's guidelines on the assessment of knowledge and competence focus on employees obtaining the appropriate qualifications and experience. The guidelines will apply in the UK from 3 January 2018.
The ESMA guidelines include some concepts new to the UK including:
- A maximum time period of four years during which employees need to acquire knowledge and competence;
- A minimum time period of six months for employees to be considered eligible to have acquired appropriate experience.
The FCA will transpose Article 25(1) of MiFID II into SYSC 5, to apply to all common platform firms. To achieve compliance with the ESMA guidelines, including the two new guidelines above, the FCA will amend the Training and Competence sourcebook (TC), SYSC and publish material on the FCA website. The FCA notes that the existing rules and guidance in TC and SYSC are well placed to help firms meet their guideline requirements.
2.3. Recording of telephone conversations and electronic communications (taping)
MiFID II introduces for the first time an EU-wide requirement for firms to record telephone conversations and electronic communications when providing specific client order services that relate to the reception, transmission and execution of orders, or dealing on their own account. The UK has had a taping regime in place since 2009, which is very similar to the new MiFID II regime. The FCA will consolidate the rules into SYSC.
The FCA proposes to apply the MiFID II taping regime to a wider range than those required by the MiFID II, namely:
- The service of portfolio management, including removing the current qualified exemption for discretionary investment managers;
- Corporate finance business;
- Energy market activity or oil market activity;
- Activities of collective portfolio managers (full‑scope UK AIFMs, small authorised UK AIFMs and residual CIS operators, incoming EEA AIFM branches and UCITS management companies).
The requirement for phone taping is not new to investment firms, however there are some key differences to be mindful of:
- The retention period is longer than the existing regime (six months). MiFID II requires records to be stored for five years, with the option for the Competent Authority to extend the requirement to seven years in specific cases;
- The MiFID II provisions require recording of conversations and communications with all clients where these relate to/intend to lead to the conclusion of a transaction, even where the transaction is not concluded. Under the current regime, only such conversations and electronic communications with professional clients and eligible counterparties are caught;
- The MiFID II provisions apply to all MiFID financial instruments rather than qualifying investments only;
- Unlike the current regime, MiFID II does not include any exemptions or exceptions to the requirement to record.
2.4. Supervision manual (SUP), authorisation and approved persons
The FCA proposes a new FCA Form, Form A, which incorporates the additional information on organisational structure and a firm's management body when applying for authorisation required by MiFID II and underlying technical standards. Form A will be available from the beginning of 2017 and will be used by:
- New firms applying for authorisation to undertake MiFID activities;
- Existing non-MiFID firms applying for a variation of permissions which will bring them within scope of MiFID;
- Prospective Article 3 firms applying for authorisation.
2.5. Perimeter guidance (PERG)
The FCA proposes to update PERG to clarify the scope of MiFID II by providing guidance on:
- The meaning of personal recommendation for the purposes of MiFID II;
- The scope of the expanded financial derivatives category, notably in relation to FX products (such as FX Forwards) as provided in Article 10 of the MiFID II Delegated Regulation. The FCA notes that 'derivatives' has been extended to derivative instruments relating to securities, currencies, interest, emission allowances or certain other things. This amendment represents a departure from the previous UK position that these derivatives did not fall under MiFID I. Spot foreign currency contracts and foreign currency transactions connected to a payment transaction continue to fall outside MiFID II;
- The scope of the amended commodity derivatives category;
- How are emission allowances treated under MiFID II;
- The scope of the exemptions for professional firms and commodity trading firms under MiFID II.
How DLA Piper can help you
DLA Piper advises some of the largest financial services companies and institutions on both their day-to-day operations and wider strategic objectives. We help our clients of all sizes contend with legal issues, including regulatory demands and the compliance costs that come with reform. Our specialist Europe-wide regulatory financial services lawyers offer market-leading insight into the development and implications of MiFID II and associated FCA regulatory change.
If you need particular advice on how the UK implementation of MiFID II will impact your business, please contact the authors.


text: The Portable Hawthorne includes writings from each major stage in the career of Nathaniel Hawthorne: a number of his most intriguing early tales, all of The Scarlet Letter, excerpts from his three subsequently published romances—The House of Seven Gables, The Blithedale Romance, and The Marble Faun—as well as passages from his European journals and a sampling of his last, unfinished works. The editor's introduction and head notes trace the evolution of Hawthorne's writing over the course of his long career: from the tales, to their apotheosis in The Scarlet Letter, through his popular romances, to his private journals and frustrated attempts at another romance. Readers looking for a critical vantage point from which to see Hawthorne whole—his artistic rise, triumph, and sad decline—can find it in this collection.

subset: commoncrawl


text:
Nokia 6.1 Sport cases
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The gym at the Olympics
The gym today gathers very different forms of sports disciplines, practiced for leisure or competition: artistic gymnastics, rhythmic gymnastics, trampoline, acrobatic gymnastics, aerobic gymnastics, tumbling
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We suggest you use this print to create your messi case or a messi t-shirt or other products just as cool and fun to use everyday.
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Who is the best paid Cristiano or Messi 2018?
It's everyone's turn. Argentina's Lionel Messi has surpassed Portuguese rival Cristiano Ronaldo in the ranking of the highest paid footballers in 2017-2018, according to the figures of the weekly France Football. Messi won a whopping $ 126 million, with Cristiano Ronaldo at € 94 million..
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text:
The Modern MACH Man
So there we have it: the ultimate in wearable computing, a compact, subcutaneous computer able to communicate by speech. This being the modern age, of course it would have wireless links too - cellular for range and ubiquity - for interrogating remote databases plus GPS to keep our secret agent on track to his destination and to find the quickest escape route. Again, all this is possible now: we have the technology, we have the capability.
The question is, of course, whether our man would need it at all. The very technology that would allow a computer to be miniaturised and embossed on a secret agent's skull as per the original MACH 1 is already there in his hand: it's his phone.
Give him a hands-free headset and a feed from base, and he can be continually aided by humans at home who can monitor his progress using military grade GPS tech and, at least while he's outdoors, satellite-mounted cameras. Modern agents don't need to undergo expensive surgery to get real-time data feeds - just a trip to a local Carphone Warehouse.
That's the trouble with looking ahead an wondering how technology might evolve. Writers often get the broad thrust right - as Pat Mills did, anticipating the miniaturisation of advanced compute power - but when it comes to details they are usually out by miles. They're interested in what we can't do now but would like to. But they forget that it's the technologies we discovered but didn't know what they might make possible that change the world.
Take the microprocessor. Integrating circuits is one thing, and a necessary step toward the greater miniaturisation of electronics, but using the technique to create a programmable logic device that, at first, was less powerful than any computer of the time... well, no wonder Intel, back in the 1960s when the first microprocessors were being created, thought its future lay in memory chips. Even if the company could have foreseen the personal computer revolution, and perhaps made the logical leap off the desktop and into users' hands, would it have conceived a world just 50 years hence when people own laptops, desktops, tablets and smartphones, all of them general purpose computing devices?
Pat Mills at least envisaged an interesting new form-factor: the cranium. Of course, he created MACH 1 to entertain ten-year-old boys, not forecast the future. John Probe's computer ally is a plot device first, prediction second, and an unintentional one at that. Post World War II science-fiction is rarely deliberately predictive. Any fiction set in the future is going to make implicit predictions about what technology humans will be using at that time, but it's important not to forget that these 'forecasts' are first and foremost tools to help tell a story.
Whether forecast
Think about Star Trek, perhaps the most enduring example of SF widely believed to be intentionally predictive, especially by Americans working in the technology industry, most of whom seem to be Trekkies. The show's Communicator is held by some to be a mobile phone prototype, but it's really just a futuristic walkie-talkie. There's no indication everyone in the Federation or beyond possesses such a device and uses it not only to talk to people over great distances but to read the news, play games, to navigate on foot, to tell other folk what they're currently doing, and to take pictures. Star Trek: The Next Generation may have miniaturised the Communicator into a badge, but it's still just a voice device, not a smartphone.
Not to pick on Trek - few novels, comics, films or TV series forecast what mobile phones have become and their impact on today's society let alone tomorrow's. Those that hinted at widespread phone use didn't see text messaging coming or - despite the Sony Walkman - that we'd be downloading music to them. Most SF authors who got wind of the internet in the 1970s and 1980s didn't suggest we'd be turning to it on mobile devices for daily news and telling World+Dog in 140 characters or less what we're doing at any given moment. There is no Twitter, no Facebook in William Gibson's early novels, for instance.
Just like MACH 1's cranial computer, it's easy to come up with 'impossible now, possible sometime' technologies, but rather harder to work out whether they'll find a use - and even more to spot other technologies that make them redundant. ®
Sponsored: How to simplify data protection on Amazon Web Services


text:
Federal Reserve Chair Janet Yellen said Friday that the case for raising short-term interest rates "has strengthened in recent months," NBC News reported.
Yellen, speaking at the central bank's summit in Jackson Hole, Wyoming, cited "solid performance of the labor market and our outlook for economic activity and inflation."
But she stopped short of confirming that the hike could come in September. In December the Fed approved its first rate hike -- up a quarter-point -- in more than nine years.
U.S. & World
The Dow shot up more than 100 points in morning trading after her speech, but dropped deeply by noon. It recovered to post 53-point losses by the closing bell.
A wobbly economy, low inflation and turmoil abroad has kept the Fed from continuing rate normalization, CNBC reported.


text:
Police Story
If we lived in a perfect world, Police Story would be the archetypal action film all other action films would emulate. But the world is imperfect and most action films are bloated, $100 million plus productions filled with bad dialogue, aging stars, poorly choreographed fights, and CGI removing any semblance of real threat or excitement. And yet, Police Story is almost thirty years old and still excites in the way action movies should.
Police Story doesn't wait around to give you tons of unnecessary exposition. Right from the start, it spends only a few minutes establishing who the bad guys are, why the cops are after them, and Chan Ka-Kui's (played by Jackie Chan, also the film's director) moralistic view of his job. And right when they give you just enough info to get involved in the story, you're treated to a gunfight followed by cars driving through and destroying an entire shanty town followed by Chan Ka-Kui chasing a bus being held hostage by the escaping villains.Continue Reading


text:
Narrative of the Life of Frederick Douglass is a memoir and treatise on abolition written by famous orator and ex-slave, Frederick Douglass. It is generally held to be the most famous of a number of narratives written by former slaves during the same period. In factual detail, the text describes the events of his life and is considered to be one of the most influential pieces of literature to fuel the abolitionist movement of the early 19th century in the United States.
Language: English
Published in: 1845
Word count: 40,301 words (≈ about 3 hours)
Source: http://www.gutenberg.org/etext/23
Copyright: Public Domain
Books featured in my Sparknotes Literature 101 compilation ISBN 1-4114-0026-7. Since they are available on feedbooks for kindle and other devices,...


text:
The American Democracy Project
Welcome to the American Democracy Project (ADP) developed by the American Association of State Colleges and Universities (AASCU) in collaboration with the New York Times.
The American Democracy Project is a multi-campus initiative that seeks to create an intellectual and experiential understanding of civic engagement for undergraduates enrolled at institutions that are members of AASCU. The goal of the project is to produce graduates who understand and are committed to engaging in meaningful actions as citizens in a democracy.
The national project is directed by the American Association of State Colleges and Universities: a project co-director comes from The New York Times. Direction and support comes from a group of presidents and chancellors that serve on the AASCU Committee on the Undergraduate Experience; operational guidance come from a group of chief academic officers who serve as the Implementation Committee. The project is assisted by a number of colleagues that work in civic engagement and related fields who serve on an Advisory Committee.
The ADP Project focuses on undergraduates enrolled at institutions that are Members of the American Association of State Colleges and Universities (AASCU). The project grows out of a concern about decreasing rates of Participation in the civic life of America in voting, in advocacy, in local grassroots associations, and in other forms of civic engagement that are necessary for the vitality of our democracy. The goals of the project are
- to increase the number of undergraduate students who understand and are committed to engaging in meaningful civic actions by asking participating institutions to review and restructure academic programs and processes, extracurricular programs an activities, and the institutional culture;
- to focus the attention of policy makers and opinion leaders on the civic value of the college experience.
The American Democracy Project uses the definition of civic engagement proposed by Thomas Ehrlich and his colleagues in Civic Responsibility and Higher Education:
Civic engagement means working to make a difference in the civic life of our communities and developing the combination of knowledge, skills, values and motivation to make that difference. It means promoting the quality of life in a community, through both political and non-political processes." (Preface, page vi)
"A morally and civically responsible individual recognizes himself or herself as a member
of a larger social fabric and therefore considers social problems to be at least partly his or her own; such an individual is willing to see the moral and civic dimensions of issues, to make and justify informed moral and civic judgments, and to take action when appropriate." (Introduction, page xxvi).
Purdy, J. (2003) "Suspicious Minds". The Atlantic Monthly. January/February 2003.


text:
A PASSENGER on a double decker bus had to duck down when it crashed into a bridge.
The bus was travelling along Hawk Hill, in Battlesbridge, when it hit the bridge at 6.45pm yesterday.
A man on the top deck narrowly avoided injury by ducking down. He did not need hospital treatment.
An ambulance service spokesperson said: "The roof was completely off so luckily there was only one man on the top deck of the bus with a minor arm injury. He didn't even require hospital treatment but there were two passengers downstairs who were very shaken, one of which was taken to Broomfield Hospital as a precaution."


text:
Woll beer de las manos del «Capitán SurfRocker»
Hoy el post es de música surf, longboard y mucho sabor a birra. Os quiero presentar el cartel de presentación de la cerveza diseñada en Hossegor (France) lugar conocido por sus olas y campeonatos como el Quiksilver Pro France. Este viernes en el Holandés Errante en Burriana, Castellón, veremos al Capitán SurfRocker en acción.
Esta cerveza diseñada en Hossegor y fabricada en Alemania está haciendo hueco poco a poco entre los eventos relacionados con el surf, conciertos, etc…Es un producto que publicitariamente se está dirigiendo al sector del surf y skate, pienso que por su imagen y fuerza que tiene hoy en día este deporte en el mercado….
-si si lo puedes decir el surf está de «moda» y vende.
Luego le añadimos el lugar de donde nace Woll, Hossegor capital del surf europeo desde el año 2012. Con un diseño de packing con sensivilación con el medio ambiente usando productos reciclados y siendo su producción también ecológica, reduciendo sus gases emitidos en la producción, más un ahorro energético en la fabricación. Y por último el diseño de la etiqueta, con un Longboarder ¡Si señor! ya era hora que deje de salir el típico surfero, por fin un tablonero. Por esto se merce un diez, es más, le da un toque más clásico, a la vez moderno por la tipografía que usa.
Este punto de clásico y moderno lo podemos ver en su web cuando nombra la forma de fabricación y metodos que usán para elaborarla.
«Producción Woll La cerveza es una mezcla de artesanía tradicional de elaboración de la cerveza y la tecnología moderna para la fermentación. Este método revolucionario permite malta explotación particularmente intensas que permite Beer Woll tener su carácter propio»
Vídeo:WOLL-BEER from THEDROPIN on Vimeo.
Y sin más palabras os pongo lo fuerte del post. ¡FIESTÓN SURFER!
Como en Burriana quieren más ganas de fiestas tras estas Fallas , han pensado en montar una buena con la presentación de Woll beer, como ya dice un buen amigo la mejor forma de quitar la resaca es con cerveza ; ) No se si tiene razón o no pero me lo doy por creíble.
Este viernes presentación de una cerveza diferente, para gente diferente, la cerveza que cada vez más beben los surfers, en exclusiva en toda la provincia de Castellón ¿Qué puedes pensar cuando nombras Burriana+Longboard+Fiesta, pués al gran carísmatico y longboarder classic Pepe Birra, conocido también como «Capitán SurfRocker» detrás del micro
Lugar: Holandés Errante, Avda. Mediterráneo, 24 Burriana–Castellón
Hora: 23:45
¡Este viernes podemos decir que es el «gran viernes santo surfer»!
Os aseguro buen rollo, buena música.
Quiero también decir a tod@s, si bebes no conduzcas, seguro que tienes un amig@ que solo beba agua o refrescos que esté encantad@ de llevarte a casa o el salvador «taxi»
Un saludo y buenas olas.
*imágenes de Woll
Temas: Artículo, Burriana, Comunitat Valenciana, Fiesta, longboard, Noticias, Surf Report, Woll
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World Heritage: Monumental Sites
Valerio Terraroli
Skira, 2003 - Travel - 383 pages
This second of the three-volume UNESCO World Heritage series examines "monument structures" sites that can be seen as an essence of their cultures. The UNESCO World Heritage program selected 47 monuments based on historical importance and stylistic variations employed for the exercise of political power, social prestige, luxury, religious worship, and collective memory. The panorama includes the Taj Mahal of Agra, the Forbidden City in Beijing, the Basilica of Saint Francis of Assisi, the Temple of Borobudur, the Alhambra, the Kremlin, the Pueblo of Taos, and one of the most recognized monuments to a historical moment-the Statue of Liberty. Taken together, these sites are a timeline of civilization that range from the pyramids at Giza to the modernist buildings designed by Victor Horta in Brussels.
Travelers will revel in the possibilities; historians and students will turn to the rich text describing the heritage of every nation and every individual.
From inside the book
Try this search over all volumes: Emergency
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Monumental Sites : Treasury of World Culture Series UNESCO World Heritage (World Heritage)User Review - Not Available - Book Verdict
This lavishly illustrated work is the second of three volumes in the "UNESCO World Heritage" series, which draws from some 700 sites on the World Heritage List to present works thematically. This ... Read full review
Treasury of World Culture : Archaeological Sites and Urban Centers UNESCO World Heritage (UNESCO World Heritage)User Review - Not Available - Book Verdict
For more than 30 years, the World Heritage Committee of the United Nations Educational, Scientific, and Cultural Organization (UNESCO) has identified and documented sites that represent "the cultural ... Read full review
The Palace and Gardens Roberta DAdda
i 122
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Common terms and phrases
adorned aisles ancient apse arches architect architecture artists Avalokitesvara Baroque basilica Borobudur Buddha building built carved Castel del Monte castle Cathedral ceiling central centre century Chapel Chinese Christ church colours columns complex construction court courtyard crowned culture Dalai Lama decorated depicting designed dome Dynasty emperor entrance Escorial facade facing floor Forbidden City fortress fountains Francis Frederick French frescoes gallery garden Gothic Gothic architecture grottoes hall imperial interior Italian king Kremlin layout located Luigi Vanvitelli Mahal marble monastery monumental mosque motifs Mount Athos nave octagonal original painted palace park pillars Pirro Ligorio portal Potala punctuated pyramid Ramesses II residence Rococo Roman roof rooms royal Saint sanctuary sculptures Shah Jahan side square staircase stands statues stone storeys structure stucco style surrounded symbol Taj Mahal temple terrace tion tomb Tower transept tury UNESCO added upper vault walls wooden World Heritage List


text:
History of Medicine
Reference Services and Information
The History of Medicine Reference staff responds to history of medicine inquiries from across the U. S. and abroad by e-mail, telephone, mail, fax, and in person.
Reference staff members are available to help researchers during regular hours, Monday-Friday, 8:30 a.m.-5:00 p.m. (EST), except on Federal holidays. Material is retrieved from the stacks to the History of Medicine Reading Room on the hour from 9:00 a.m.-4:00 p.m.
- Ask a Reference Librarian
- How do I look for...
- Books, journals, historical images, and films?
- Islamic and Western manuscripts?
- A person or organization's papers?
- Sources for genealogical and biographical research?
- Information on the history of NIH?
- Information on the history of NLM?
- Journal articles in the history of medicine?
- Primary source material in the history of medicine?
- NLM historical material that is online?
- How do I borrow (interlibrary loan)?
- How do I request copies?
- Donations and Appraisals
- Forms and Policies
- Copyright Information
- Frequently Asked Questions (FAQs)
Ask a Reference Librarian:
Contact a Reference librarian at the History of Medicine Reference desk by phone 8:30 a.m - 5:00 p.m. (EST) Monday - Friday or send an e-mail or fax.
Reference Librarians: Stephen Greenberg, Anne Rothfeld, Crystal Smith
Phone: 301-402-8878
Fax: 301-402-0872
E-mail: firstname.lastname@example.com
How do I look for...
Books, journals, historical images, and films?
Search for books, journals, images and films in the Library catalog (LocatorPlus). Historical images can also be searched in the Image database (IHM). See also Using the Collections.
Islamic and Western manuscripts?
Search Islamic manuscripts in Library catalog (LocatorPlus). Many but not all Western manuscripts are in LocatorPlus. See a complete list of Western manuscripts in Early Western Manuscripts in the NLM: A Short Title List.
A person or organization's papers?
The Archives and Modern Manuscripts Collection can be searched in the Library catalog (LocatorPlus). Manuscript collections are identified by an "MS" call number. Oral histories have an "OH" call number.
For more information see Archives and Modern Manuscripts Program.
Sources for genealogical and biographical research?
Historical collections include medical biographies, medical directories, and obituary indexes, primarily from the 19th century. See Selected Sources for Biographical Information about 17th-Early 20th Century American Physicians (pdf). An especially useful source is the Directory of Deceased American Physicians, 1804-1929, published by the American Medical Association. This directory is available in the History of Medicine Reading Room, and at many large research and medical school libraries.
For information to help you prepare for your genealogical research at NLM, please see Genealogical Research in the History of Medicine. While there are no actual records, you will find bibliographical citations, finding aids, and information on how to conduct research using a variety of materials in the collection.
Information on the history of NIH?
See Historical Resources at the DeWitt Stetten, Jr., Museum of Medical Research web site.
Information on the history of NLM?
See A Brief History of NLM, The Story of NLM Historical Collections, and NLM Archives.
Journal articles in the history of medicine?
To find journal articles in the history of medicine, use the following online and print resources:
MEDLINE/PubMed (Online) - To find journal articles in the history of medicine that were published after 1964, click Limits on the PubMed homepage and select Subset History of Medicine.
For articles published from 1958-1965, select Subset OLDMEDLINE for Pre1966.
For information about PubMed, see FAQ MEDLINE/PubMed and Other Databases.
Bibliography of the History of Medicine (Print) - Includes journal articles, book chapters, and conference papers and proceedings published from 1965-1993. The Bibliography is a print version of the discontinued HISTLINE database.
Index-Catalogue of the Library of the Surgeon-General's Office (Print) or IndexCat (Online) - Includes journal articles in the history of medicine published from the 17th-20th century.
Index-Medicus (Print) - Index to journal articles in biomedical journals worldwide published from 1879-1927.
Primary source material in the history of medicine?
The printed Index-Catalogue of the Library of the Surgeon-General's Office (online version IndexCat), U.S. Army (61 volumes in 5 series, 1880-1961) is a valuable resource, especially for pamphlets, dissertations, and journal articles from the 19th and early 20th centuries.
Index Medicus (1879- ), which indexes articles in the medical journal literature, is another useful resource that is widely available.
The Bibliography of the History of Medicine, a printed version of the discontinued HISTLINE database, was published in six cumulative volumes (1964-1993), and is useful for pre-1993 material.
For more information, see Printed Catalogs and Guides.
NLM historical material that is online?
Selected material from historical collections can be viewed in Online Exhibitions, Related NLM Web Sites, and digitized books, manuscripts, and pictures. For a complete list of digitized historical material, see Digital Collections.
How do I borrow (interlibrary loan)?
The Library does not lend historical material in its original format; however, we do lend copies of journal articles; copies of selected manuscripts; books; and manuscripts on microfilm (when available); and copies of films and videos. The Library's interlibrary loan services are available only to libraries, not to individuals. Individuals who want to borrow NLM material should make a request through a local library. For more information see Interlibrary Loan Fact Sheet.
How do I request copies?
How to get photocopies of NLM historical material
Self-service photocopying of historical material is not permitted. For onsite patrons, History of Medicine staff will do limited photocopying for a fee of 20¢ per page, depending on the condition of the material. Patrons may pick up completed orders at the History of Medicine Reading Room or have them mailed free of charge.
Off site requests for photocopies of journal articles require an interlibrary loan request. See How Do I Borrow?
How to get copies of pictures from books, journals, manuscripts, etc., in NLM historical collections
The Library has arrangements in place with an approved photographer, who, at the discretion of the History of Medicine Conservation Librarian, performs onsite photography of material from historical collections. The photographer visits History of Medicine at least once a month. Patrons make billing and shipping arrangements directly with the photographer.
Before requesting photographic services, read the following forms:
- Photographic Services: Information and Instructions
- Photographic Services: Price List
- Photographic Services: Request Form: Patrons must complete this form, sign, and return via mail or in person.
For more information Ask a Reference Librarian.
See also Photographic reproductions at the Archives and Modern Manuscripts Program page.
Note that Historical Collections Copyright Information applies to all photographic reproduction requests.
How to get copies of NLM historical pictures and films
For prints and photographs, search the Images from the History of Medicine (IHM) database and see Order Images on the IHM homepage. Also see Prints and Photographs.
To purchase copies of films and videos, see How to Access and Use Films and Videos. See also Films and Videos.
How to purchase microfilm
Some books and manuscripts in NLM historical collections have been microfilmed and are available for purchase. The item's LocatorPlus record indicates if that item has been microfilmed. For information about purchasing microfilm, see the Microfilm Sales Program Fact Sheet or Ask a Reference Librarian Fact Sheet.