According to the letter of the law, investment firms may not pay or receive commissions with effect as of 1 January 2014. However, most of the invoicing and collection of commissions earned in the fourth quarter of 2013 will take place in the first quarter of 2014. Is this allowed?

The AFM states that collection of commissions earned in 2013 in 2014 Q1 is allowed. The ban on inducements is intended to stop commissions as of 1 January 2014 and collection of fees in 2014 Q1 relates to services provided prior to 1 January 2014. In any case, this only applies to lead commissions and return commissions, because a transitional regime will apply for kick back fees until 1 January 2015.

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