7. Does the moratorium apply to discretionary portfolio management or private placements?

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.