The moratorium does not apply to discretionary portfolio management. There is no exception made for private placements with retail investors. The moratorium does, however, provide for an opt-out, under certain conditions, for clients with moveable assets of at least EUR 500,000 held with one institution. The decision whether to make use of the opt-out is up to the distributor who signs on to the moratorium, and the decision taken applies to the entire category of eligible clients. The opt-out is therefore not a decision that a client can make on a case-by-case basis.
