France's Autorité des marchés financiers has issued a supervisory reminder on the use by financial investment advisers (conseillers en investissements financiers, CIF) of platforms that reference and analyse financial products and may also provide documentation templates and tools. The AMF notes that using such platforms, even where they have a regulated status, does not in itself breach the rules but does not relieve CIF of their professional obligations to clients. The AMF highlights cases where CIF sign contractual arrangements committing them to generate a majority of their turnover from platform-referenced products and to remit part of that revenue to the platform, while client communications may still suggest “independence” from the platform despite a significant business relationship. CIF must provide clear, accurate and non-misleading information about how they operate, and remain responsible for compliance when relying on third parties. In particular, CIF must not rely passively on platform analyses and must carry out their own diligences to understand products, assess target market compatibility and suitability, and avoid recommendations driven by contractual incentives. The reminder also reiterates annual training expectations and the requirement to refrain from advising on products whose economic or legal features are not mastered, and it clarifies that a platform’s possible CIF status is not appropriate where it does not actually provide investment advice and does not permit services such as non-guaranteed placement, with strict limits on order reception and transmission. The AMF further restates that marketing financial instruments must take place within the investment advice service and be supported by the required regulatory documentation, client information gathering, risk disclosure, remuneration transparency and conflict-of-interest controls.

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