What records should be kept by firms when providing underwriting or placing services and how should firms justify their final allocations to each investment client?

Article 38(1)(d) of the MiFID II Delegated Regulation states that “investment firms which provide advice on corporate finance strategy, as set out in Section B(3) of Annex I, and provide the service of underwriting or placing of financial instruments, shall, before accepting a mandate to manage the offering, have arrangements in place to inform the issuer client of the details of the targeted investors, to whom the firm intends to offer the financial instruments”. Are investment firms required to provide details of each individual investor client or per type of investor client?

How can a firm provide ex-post information on total costs and charges more regularly (e.g. on a quarterly basis)?

The cumulative effect of the costs on the return shall show “anticipated spikes and fluctuations of the costs”; does that also apply to the ex-post disclosure of the cumulative effect of the costs on the return?

To what extent does the cumulative effect of the costs on the return need to be graphically displayed?