Regulatory Services

The Regulatory Services service group bundles functionality related to assessing a user's or client's suitability for an investment proposal.

Overview

The regulatory services endpoints are grouped into several resources, all placed under the path "/reg/v3/mifid".

They are currently supported only in the context of investment advisory!

Appropriateness

This resource represents the instrument specific appropriateness of a given person when considered in the context of advisory (i.e. suitability). The information may be captured through one of Saxo's platforms, but it is possible to use the GET endpoint in the appropriateness resource to capture the result of the assessment.

The API is designed for further extension, hence one of path parameters is the RegulatoryContext, which - currently - can only take one value "Advisory".

For each AssetType we register:

• Status: Was the test taken, and if so what was the result: ( Product is Appropriate or Product is not Appropriate)
• IsComplex: Is the product considered to be complex.

It is the combination of (AssetType and IsComplex) which is the key for the Status. You can have "Listed Equities" (which are not Complex) and "Unlisted Equities" (which are Complex), and in both cases they will have AssetType=stock.

Sample Request/Response

GET/reg/v3/mifid/appropriateness/OV6ZL2-AYB0VvW2FzEqz7A==/Advisory

Returns: 200 OK
{
    RegulatoryContext:"Advisory",   
    Statuses: [
       {
            "AssetType":"FxSpot",
            "IsComplex":"True",
            "Status": "NotAppropriate"
       },
       {
            "AssetType":"Stock",
            "IsComplex":"False",
            "Status": "Appropriate"
       }
        .....
    ]
}

Q&A related to general knowledge

The person's general knowledge is also assessed through a number of questions. 

It is possible to use the provided GET endpoint to retrieve these questions and answers, but - currently:

• Only for the regulatory context of Advisory, and
• Only for the section related to general knowledge and experience.

Sample Request/Response

GET /reg/v3/mifid/qnasections/OV6ZL2-AYB0VvW2FzEqz7A==/Advisory/?SectionName=Knowledge-Experience

Returns: 200 OK
{
    "__count": 1,
    "Data": [
        {
            "Data": [
                {
                    "Answer": "Bachelor's degree, professional bachelor, HD",
                    "Question": "Educational level:"
                },
                {
                    "Answer": "Finance/economics",
                    "Question": "Field of work – works within/has worked within:"
                },
...
 
            ],
            "Language": "EN",
            "SectionName": "Knowledge-Experience",
            "Status": "Successful"
        }
    ]
}

Financial Overview

Using this resource it is possible to fetch and update the summary financial situation of the advised entity (either Individual or Organization)

Not all fields are allowed for both entity types:

Sample Request/Response

GET/reg/v3/mifid/financialoverviews/Individual/OV6ZL2-AYB0VvW2FzEqz7A==

Returns: 200 OK
{
    "EntityType":"Individual",
    "EntityKey":"OV6ZL2-AYB0VvW2FzEqz7A==",
    "Assets": 10000,
    "PensionAfterTaxes": 1000,
    "Liabilities": 5200,
    "DebtFactor": 3,
    "LiquidAssets": 7767,
    "LossAbility":"Normal",
    "IlliquidAssets": 7968,
    "BenchmarkDebtFactor": 2,
    "Income": 13000,
    "Expenses": 4600,
    "IncomeAfterExpenses": 8400,
    "BenchmarkIncomeAfterExpenses": 1000
}

Investment Profiles

For every account intended for managed investments there must be a record of  "Risk Appetite", "Preferred Involvement", "ESG Preference" as well as "Purpose" and "Horizon". Registration of this is often seperated into:

• "Risk Appetite", "Preferred Involvement" and "Esg preference" is registered overall on the advised entity.
• "Purpose" and "Horizon" is registered for each account.

When getting the complete investment profile for an account, we take all preferences from the entity (individual or organization) and overwrite them with any preferences that are specified at the account level.

It is however also possible to override "Risk", "Preferred Involvement" and "ESG Preference" on an individual account level.

Using the endpoints pertaining to InvestmentProfiles it is possible to fetch and update the general investment profile.

Sample Request/Response

GET/reg/v3/mifid/investmentprofiles/Individual/OV6ZL2-AYB0VvW2FzEqz7A==

Returns: 200 OK  
{
    "EntityType":"Individual",
    "EntityKey":"OV6ZL2-AYB0VvW2FzEqz7A==",
    "RiskAppetite": {
        RiskAppetitieId:3,
        Description:"You expect a return....",
        RiskAppetiteLevel:"Balanced"
     },
    "PreferredManagementType": "Advisory",
    "EsgDeclaration": {
        "EsgPreference":"ImpactMinimum20pct",
        "SpecificEsgPreference" : {
            "ImpactInvestingPct":50,
            "PrincipalAdverseImpactPct":30
            "TaxonomyPct":20
        }
  
    }
}

Account Investment Profiles

This represents the specific account profile for an individual account. The caller must at least specify "Purpose" and "Horizon".

When retrieving an account investment profile using the GET endpoint:

• If the request only specifies the account (by putting accountKey in the path), the endpoint will only return what has specifically been set for the account.
• If the request also includes EntityType and EntityKey query parameters, the endpoint will return a combination of:
  • What ever has been specified as a general investment profile for the entity identified by EntityType/EntityKey
  • Overwritten by whatever has been specified directly on the account

Sample Request/Response

GET/reg/v3/mifid/accountinvestmentprofiles/KDP9uS3Re3uwk1aBA2PdCw==&EntityType=Individual&EntityKey=OV6ZL2-AYB0VvW2FzEqz7A==

Returns: 200 OK   
{ 
    "Horizon":2024,
    "Purpose":"Pension",
    "RiskAppetite": {
        RiskAppetitieId:3,
        Description:"You expect a return....",
        RiskAppetiteLevel:"Balanced"
     },
    "PreferredManagementType": "Advisory",
    "EsgDeclaration": {
        "EsgPreference":"ImpactMinimum20pct",
        "SpecificEsgPreference" : {
            "ImpactInvestingPct":50,
            "PrincipalAdverseImpactPct":30
            "TaxonomyPct":20
        }
    }
}