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MiFID II: does the first line of defence now own ‘good’?
24 Jul

MiFID II: does the first line of defence now own ‘good’?

JWG analysis. At the turn of the century, the framers of the UK’s financial infrastructure rulebook enshrined four fundamental concepts into systems and controls practice.  The rulebook in question is the Financial Services and Markets Act 2000 (FSMA), which created the FSA.  (The FSA was then subsequently split into the FCA and the PRA in Read More

10 Jul

ESMA gets an earful from industry

By Anna Reitman, Automated Trader. Public hearing was a marathon run for industry questions and comments on every aspect of upcoming MiFID II and MiFIR reforms. We highlight a few issues, including market making obligations and requirements that could find direct market access providers identifying clients’ proprietary algorithms. Paris – As the financial industry prepares Read More

08 Jul

Know thy algo: how to define it, prove it, tame it. Part 1

JWG analysis. Regulators across the globe appear divided on the question of whether tighter control of algorithmic trading is necessary. The Australians are pretty laid back about it, the Germans are ahead of the game, whilst political debate rages in the US.  Regardless, while the value of algo trading to global markets is generally considered Read More

04 Jun

Building the MiFID II surveillance system: your checklist

In our previous article we looked at the current surveillance regime in Europe and the challenges of extending it. See here for more background on the 860 questions that need to be answered by 1 August. While not comprehensive, this will help describe three issues that should be on your checklist: context, identification and linkage. Read More

02 May

MiFID II transparency: a brave new world

JWG analysis. As the European Parliament adopted MiFID II/ MiFIR on 15 April, the financial services industry was left wondering what exactly the new transparency regime is going to mean. Despite a curiously low EC estimate of compliance costs, at between €512 and €732 million, it is clear that MiFID will have a large impact Read More

14 Apr

Top 10 MiFIR transaction reporting known unknowns

JWG analysis. When MiFIR is implemented in 2016, all of the pain experienced in preparing for EMIR’s transaction reporting regime, which went live earlier this year on 12 February, is likely to be rekindled.  Thankfully, at least this time around the industry has significantly more time to get prepared. Hopefully, that means enough time to Read More

04 Apr

Algo flagging – the future

By Sam Tyfield, Vedder Price. Algo flagging is currently only the concern of direct members of German venues.  But it’s going to have a much broader application under MiFID / MiFIR and become of concern to the buy-side too. Yesterday, the good Doctor Voigt of Fidessa published a blog about algo flagging.  It is well worth Read More

25 Mar

MiFID II / MiFIR: summer of standards 2014

JWG hosted a jam-packed CDMG meeting last week for the first sneak-peek of what MiFID II holds in store for 2016. The big conclusion:  a lot of work still needs to be done to scope out the operational implications of MiFID II / MiFIR and firms will need to coordinate responses quickly once the consultation Read More

05 Dec

MiFID II: Sum of the change requirements equals investor confidence?

Dr Anthony Kirby, Chair MiFID BEWG – E&Y MiFID II will be implemented as both a regulation, “MiFIR” (with direct effect in all 28 Member States), and a directive (requiring transposition into national law). The timing of ancillary measures such as revisions to the Market Abuse Regulation (MAR/MAD II) and the Packaged Retail Investment Products Read More