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From the Pathfinder
Business concept
How an app can become an activity that requires permission.
Research and interactive method for digital suitability →
INTERACTIVE EXAMPLE / 05
Suitability assessment · CFD copy trading
Before providing portfolio management, a firm must assess whether the mandate suits the investor. It considers knowledge and experience, financial circumstances including ability to bear losses, and investment objectives including risk tolerance. This example walks through an automatically copied CFD strategy.
Scenario: you plan to allocate €2,000 for twelve months to a CFD copy-trading mandate. Signals from a selected trader are executed without your approval of each order. The entire allocated CFD account balance could be lost. The provider must monitor the strategy, risk limits and copied transactions.
Legal basis & methodology
MiFID II · Art. 25(3)–(4) · ESMA35-43-3006
The total score is a transparent teaching aid, not a regulatory threshold. In real portfolio management, sustainability preferences require separate collection and matching against the actual strategy; return or risk points cannot replace them.
BaFin · CFD product intervention
ESMA · Copy Trading Supervisory Briefing · ESMA · Suitability Guidelines
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Across our tools & projects
Fit & Proper · skills matrix
Prepare management profiles and collective suitability reviews.
International market entry / Germany
Is Germany your next market?
Considering a local office, a branch or a standalone authorisation in Germany? The appropriate route depends on your home jurisdiction, activities and operating model. 3RMCN combines experience from complex supervisory projects with product, technology and delivery expertise: from entry strategy and key interfaces through to operational readiness.
Discuss your plans ↗Supervisory perspectives
Familiar with several regimes
Experience in the context of CySEC (Cyprus), MFSA (Malta), FCA (United Kingdom), the European ESMA framework and MAS (Singapore). ESMA is not a national licensing authority.
International structuring
Incorporating offshore?
For incorporation in offshore jurisdictions, relevant specialists from the network can be involved. Jurisdiction, activities and regulatory obligations need to be considered for each project.