RegTech IntelligenceJWG analysis. On 7 July, market experts at the City & Financial Global workshop on transaction reporting under MiFID II addressed an audience, setting out their main concerns regarding the new transaction reporting regime. In this article, we present some of the key issues that they highlighted. The European Securities and Markets Authority (ESMA) have
By Sam Tyfield and JWG. It has been widely rumoured that the level 2 MiFID II will define the high frequency algorithmic trading technique (HFATT) as one which has a high message intraday rate in which there is a minimum of four messages being sent per second for all instruments traded on a trading venue.
JWG analysis. Since 2008, regulators have been plugging the gaps revealed by the global financial crisis and have just put another brick in the financial services wall – the 4th Money Laundering Directive. Last month, the much anticipated ‘IV’ was published in the official journal and will become the law of the land in 2
JWG analysis. At CISI’s Annual Conference, Verena Ross presented the latest outlook on EU regulation, covering the Capital Markets Union (CMU), ongoing work in relation to investor protection and the digitalisation of financial services. Ross once more emphasised how a successful CMU, based on a single capital market in the EU, promotes the attractiveness of
JWG analysis. Today ESMA published a Q&A, aiming to clarify the status of investment-based crowdfunding platforms which are outside the scope of MiFID and, therefore, not automatically subject to rules designed to combat money laundering and terrorist financing under AMLD III. Investment-based crowdfunding platforms can have a different regulatory status. Some are within the scope
JWG analysis. With a number of regulatory deadlines looming, we thought we’d remind you of another one – mark January 2017 in your calendars (if you haven’t already) for MiFID II. The aftermath of the recent financial crisis exposed weaknesses within Europe’s current Economic and Monetary Union and highlighted the need to strengthen it. Although
By Sam Tyfield and JWG. While the latest chapter of the Greece tragedy plays out, today ESMA quietly released its final report on draft technical standards on the authorisations, passporting, registration of third country firms and cooperation between EU competent authorities. Compared to the Consultation Report published in December 2014, ESMA has clarified a number
JWG analysis. TheCityUK today published its research report on EU reform. In it, they outline proposals for a more competitive Europe, focusing on regulatory reform in section five. As TheCityUK emphasises, and we have previously mentioned in our publications, a spate of fresh regulation has been initiated within and beyond the G20 since the global
JWG analysis. Some of the areas in which firms are the keenest for greater clarity are transaction reporting, understanding where information on which instruments are traded on venues will come from and the overlap between MiFID and RDR. It was agreed that TAs would speak to their members and come back to the FCA with
JWG analysis. As we pointed out in our third piece on regulatory reporting, and at an Infoline conference for the buy-side this week in London, the overarching question is how will firms’ derivative activity be judged to be ‘good enough’ in 2017? There is no single answer, and we won’t really know until the results
We are now less than 400 work days away from MiFID II’s big bang and ‘implementation’ is now the name of the game. Yes, there will be a final version, but the vast majority of what is in the drafts is likely to remain the same. On 7 July, City & Financial Global will hold
JWG analysis. We are less than 115 days from the point when the first phase of new energy trading reporting obligations kicks in across the EU. Amidst a recent industry outcry to develop more consistent data reporting standards, the requirements introduced by the Regulation on Energy Market Integrity and Transparency (REMIT) are yet another example
JWG analysis. Eleven of the industry’s most high-profile trade associations and ISDA this week urged regulators to adopt consistent and harmonised trade reporting requirements across jurisdictions. However, reporting rules are already on the books and the consequences are high for firms. In part 1 of our analysis on reporting, published last week, we explored
JWG analysis. In her speech at IDX 2015 this week, Verena Ross, Executive Director, European Securities and Markets Authority, addressed the two major EU legislative projects affecting derivatives trading: MiFID II and EMIR. Here we present some of the key issues she highlighted. 1. MiFID II timeframe and technical standards The decisive date for application of MiFID II
JWG analysis. Catch phrases, like ‘caveat emptor’, have been the rallying cry of the financial industry for millennia. In 2009, the G20 sought to change the status quo by introducing the notion of global transparency to all markets. After spending billions on the first wave of reporting, we are only now realising how difficult it
JWG analysis. As we have been reporting for the past 18 months, MiFID II is massive and the delta between it and MiFID I is cavernous. JWG’s MiFID Implementation Group (MIG) weekly workshops have been actively delving into the ‘known unknowns’ of the sell-side all year and we are pleased to help promote City &
JWG analysis. Given the 5 year latency between flash crash and recent arrest, John Bates wondered whether the regulators were riding bicycles to try and catch up with the sporty cars driven by the Flash Boys, the high-frequency traders. Although HFT represents a large percentage of trading volume, what ‘it’ is and how it can
JWG analysis. European regulatory agencies were clear: firms may already be too late if they haven’t started their MiFIR implementations that need to be tested and ready in summer 2016. Speaking at a two day ‘MiFIR Reporting & Beyond’ conference attended by JWG last week, regulators, trade associations, consultants and industry practitioners we all on
JWG analysis. Since the turn of the year, we have not seen the pace of reform slow down. We could fill pages with acronyms describing the new requirements for financial institutions, but we will spare you that. We are aiming high and expanding our coverage beyond the G20 to track over 600 regulatory initiatives and
JWG analysis. JWG’s recent analysis report, the MiFID II KYC mountain, finds that financial institutions have a 12-item checklist to work through for their MiFID II KYC implementation due to the requirement for firms operating in the EU to acquire, document and agree much more information about their customer’s situation and their transacted business by
JWG analysis. We’re used to watching our document trackers spin out of control in so-called ‘quiet’ times. As we wrote in January, the last 2 weeks of 2014 year saw global FS regulators pump out over 4,000 pages. These Easter holidays were little better with 2,000 pages of regulatory text released in two weeks. It
JWG analysis. As MiFID programmes take off and top tier firms tackle MiFID II implementation, the banking sector is about to be hit by even more pressure to produce reports about trading activity. The proposed regulation, aimed at enhancing the transparency of securities financing transactions (SFTs), seeks to ‘balance the scales’ between the two sectors
JWG analysis. Firms have plenty of planes in the air right now. The regulatory pressure on firms to ‘get KYC right’ in the form of new financial crime regulation, such as FATCA or AMLD IV, and huge fines means they will need to juggle these changes amidst an ongoing regulatory implementation effort. How you need
JWG analysis. We attended an august gathering of 400+ buy-side professionals last week. Not only did regulatory drivers get a healthy hearing, but the group discussed how they will impact the way business is going to be handled in the future. Clearly, margins are under pressure, brokers are not giving it away like they once
By Sam Tyfield and JWG. Here algo again … Yesterday, ESMA published a notice stating that supervision of automated trading across the EU (in compliance with the ESMA guidelines from 2012) was converging. We found that interesting – a closer look at the BaFin’s rules versus those MiFID II/R creates would appear to show less
Regulation is coming thick and fast. With predicted document count of 200,000 by 2018, dealing with the deluge in a page-by-page, regulation-by-regulation approach is becoming impossible as G20 commitments spread across many rulebooks. Firms trying to tackle the changes one-by-one will end up with sky-high implementation costs and conflicting priorities – unless they take action
JWG analysis. Regulations like FATCA, EMIR and Dodd-Frank have asked us to collect more information on our customers than ever before – but now it’s clear that was just the start of the story. New regulation finds regulators even hungrier for information on the firm’s relationship with its customer, together with details of how information
With the second round of MiFID II consultation now officially over, the time is right to get our MiFID II implementation training ready to fly on 24 March in London. We suspect that, soon, regulators will be asking tough questions about how you plan to be ready for system integration testing in a mere 350
JWG analysis. The second round of MiFID II consultation has officially ended. As we have previously noted, the tone from the recent hearing was that, despite more consultation due on some of the fine print, we are largely done discussing the standards and can now begin to start thinking about how to implement them. On
JWG analysis. With 40+ regulations covering 500+ KYC data requirements due to be implemented over the next 3 years, meeting the requirements poses significant challenges to all firms in the market, not least client outreach, data management and multiple, iterative, implementation dates. Combined with record fines for AML failures, and new personal liability for senior
JWG analysis. This month, ESMA hosted a broad cross-section of market participants for a final ‘hearing’ on the MIFID II technical standards they will send to Brussels for approval this summer. Of course, many attendees were surprised to find that, while they were en route to Paris to sit for 10 hours with 350 of
JWG analysis. As we read the comments on our last article on the five tribes of regulatory reform, we were struck by the visceral reaction to the suggestion of sharing the agenda. “Hands-off, that’s my mortgage you’re messing with”, commented one lawyer. We wonder, can tribes achieve their overarching regulatory goals if they are NOT
By Robin Poynder, FMR advisory. Advancements in price distribution technologies and the advent of high frequency trading have forced firms’ IT departments to establish strict controls around best practice pricing for trades. CEO of FMR Advisory, Robin Poynder, explains the need for a standardised protection mechanism “last look”. “Some argue that last look is a
JWG analysis. It’s only February and we’ve laid out quite a programme of work for 2015. Digesting the 4,000-page Christmas gift, curing the KYC sickness, cutting a trail through MiFID II and taming your global trading troubles – and we’re not yet at the midpoint of the first quarter. Sadly, it is not a blip
JWG analysis. There is a war going on to ‘Know Your Customer’. As regulators continue to release new requirements for firms to collect and maintain information about their clients and counterparties, the struggle to comply has turned into trench warfare fought across many fronts, and new strategies are needed to avoid a long and uncertain
On the 22nd January, over 30 stakeholders from 12 firms met Customer Data Management Group (CDMG) meeting to discuss their 2015 priorities for regulatory KYC requirements. JWG presented a summary of 40+ new regulations that require firms to manage counterparty information over the next 3 years. Alec then presented summaries of the 11 regulations in scope
The need for better counterparty information sits at the centre of most regulatory reform agendas. Unfortunately, this means the period from 2015 to 2017 brings with it massive new documentation, workflow and vendor change for the hundreds of fields maintained for every subaccount in capital markets. Do you know what is about to hit your marketing,
By Sam Tyfield, Vedder Price. Back in 2009, the EU issued a Recommendation (which has no binding legal effect) on the use and application of RFIDs (which, for our purposes, means ID/swipe/access cards). The EU has just issued a review of the implementation of the Recommendation EU-wide and has found take-up by EU member States
JWG analysis. The chief of the CFTC pronounced from Japan this week that implementing regulatory reform means overcoming “legal traditions, regulatory philosophies, political processes, and market concerns”. Looking at the global trading regulatory climate that surrounds MiFID II, we couldn’t agree more. Those struggling to digest the MiFID II texts and get to Paris for
JWG analysis. The industry returned after the break knowing that it had fewer than 500 working days to implement MiFID II but found over 2,000 pages of new text to read. Even worse, the grapevine whispers that more is due out this month. As we’ve written before, organising and planning is the order of the
JWG analysis. 2015 will see a number of new regulatory requirements, long in the proposal or draft stage, crystallise into prescriptions for better customer data management. At a time when record fines for AML failures and new personal liability for senior managers have intensified the pressure to ‘get KYC right’, these ‘remedies’ pose significant challenges
Happy New Year! Many may have been disappointed by snowless mountains this year but here, in the FS sector, our regulators are making sure we’re covered. Far from a light dusting, this year’s ‘Christmas dump’ exceeded our expectations and all corners of the earth are now digging out from under the 4,000 pages that fell
JWG analysis. While most of us basked in the holiday spirit, the regulatory Grinches were hard at work. In the two-week period between 19 December and 2 January, regulatory bodies in the UK, EU and US alone published over 40 critical documents. JWG’s tracking revealed a broad range of subjects. CRD IV/CRR, BRRD, UCITS V,
JWG analysis. 60 attendees across the buy and sell-sides came together at Markit’s seminar in Stockholm last month to discuss today’s industry challenges. They concluded that a new focus on establishing a flexible banking operating model to meet both business and regulatory demands for data, processes and standards, is top on their wish list for 2015.
You better know deals You better not bribe Better not launder ESMA’s telling you why MiFID II is coming to town They‘re checking reports And transparency ESMA’s regulating Intermediaries MiFID II is coming to town They see your algorithms They know your HFTs They know if you’ve been market making So follow the
This summer, we found that the industry could face up to three Eiffel Towers high worth of paper from the G20. Curious about the risks inherent in managing that many documents, we asked Meredith Gibson, Head of Legal Risk at Santander UK, and Helen Pykhova, Director of The Op Risk Company and Chair, Operational Risk
As published in ‘The Trade’. Europe’s financial regulator has revised the current framework for the reporting of derivatives trades under the European Markets Infrastructure Regulation (EMIR). The European Securities and Markets Authority (ESMA) is now seeking feedback on its changes which aim to resolve the widespread issues which have arisen in the reporting process. The
JWG analysis. In our last article on this topic, we spelt out our views on regulatory implementation standards. And the first standard that needs to be defined is how you’re going to organise your work programmes. The shape of your MiFID II programme MiFID II is far beyond just a few ‘tweaks’ to MiFID I. So much
JWG analysis. This summer, we took a look at the emerging MiFID II/MiFIR technical standards and concluded that the ‘hearing’ that they were getting would result in a war of many parts. Since the summer, over 700 MiFID II/MiFIR responses have been submitted, the FCA has run a conference crying for action and JWG is
Darragh O’Grady and JWG. There has been much written lately on the potentially disruptive impact that digital currencies may have. However, the blockchain architecture that underlies them has also been a recent subject of a CFTC meeting to discuss the potentially disruptive impact of this new technology. We asked an architecture expert with a background
Huge fines and complex KYC rules are causing banks to ‘de-risk’ their client portfolios leading to many without access to banking. Now both consumers and politicians are unhappy. For years, the industry has struggled without real standards in the AML arena. So what happens next? SIBOS news was full of more KYC claims again this
JWG analysis. The challenges of gaining oversight over the financial system are not going unnoticed. We come back from the summer holidays with 5 leading indicators that suggest we are on the brink of bad news. Bad news that is likely to spread far and wide. Firstly, in a new report, the US Government Accountability
In our previous articles we’ve explored the expanding requirements for robust systems and risk controls under MiFID II, the nature of proportionality as it relates to algorithmic trading and the new accountability implications for senior managers. This article, written by Meredith Gibson, Head of Legal Risk, Santander UK plc and Helen Pykhova, Director, The Op
JWG analysis. As the sun slips back into hibernation, schools reopen and autumn looms, regulators, lawyers, risk specialists, change managers and compliance professionals are returning to their desks. Here at JWG we have been busy tabulating the enormous level of movement in the regulatory space during the summer. For those of you lucky enough to
JWG analysis. “When providing investment advice or portfolio management the investment firm shall obtain the necessary information regarding the client’s or potential client’s knowledge and experience in the investment field relevant to the specific type of product or service … so as to enable the investment firm to recommend to the client or potential client the
Are you enjoying your summer? Ready for some holiday reading? Our latest members-only newsletter, RegBeacon, is now available here (after logging in, you can find RegBeacon on the publications page). We’ve highlighted the key issues and trends to be aware of as we head into what is sure to be a very rocky Q3 –
JWG analysis. This summer, regulatory pressure on financial services firms has ratcheted up to unprecedented levels. Many may have breathed a sigh of relief as Dodd-Frank rule-making slowed … but the respite was only fleeting. Since July, the industry has been bombarded with 39 new consultation papers (in the EU and UK alone) just as
JWG analysis. ‘What is proportional?’ is a question that firms may well find themselves pondering in the coming months as they begin implementation planning for MiFID II … and the same question is going to be asked by risk and compliance specialists on a regular basis once MiFID II goes live in 2017. This is
By Sam Tyfield, Vedder Price. Recently, ESMA published two consultation papers (CPs) on MAR: 1. draft technical standards on MAR (CP1) and 2. draft technical advice on Commission delegated acts (CP2). The consultation period closes in October 2014. CP1 contains reference to insider trading, buy-backs and stabilisation, market soundings and other issues on which I
JWG analysis Europe has two key market abuse rule-sets being introduced in 2014/15 – The Regulation on Energy Market Integrity and Transparency (REMIT) and the Market Abuse Directive (MAD) and Regulation (MAR). This month, 4 consultations have been released; two from the Agency for the Cooperation of Energy Regulators (ACER) and two from the European
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
By Jon Watkins, The TRADE. Regulators are set to clamp down on widespread trade reporting breaches across Europe as a six-month grace period since the rules were introduced expires, according to industry sources. Issues surrounding unique trade identifiers (UTIs), legal entity identifiers (LEIs) and the complexity of the 85 fields required by regulators have plagued
JWG analysis. We learnt something this month. The reason Europe calls it a regulatory ‘hearing’ is that it is an opportunity to hear views from both regulators and the market. Of course, that’s just part of the experience as many other senses are triggered when 400 people are locked in a basement for 2 days,
By Jon Watkins, The TRADE. European regulators opened their doors to market participants this week, who had their voices heard on the key points of MiFID II relating to the derivatives markets. Trade reporting, open access to clearing houses and high-frequency trading were just a handful of the contentious topics discussed during an two-days of
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
JWG analysis. The desire for tighter controls on algorithmic trading is growing globally. Trading rules in the major financial centres will quickly set new minimum thresholds. As described in our previous piece on how algos are defined and controlled, Europe is again leading the pack and would appear to have serious intent to change the
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
By Dominic Hobson, COOConnect. If you are a hedge fund manager, it is always tempting to believe that you are too small to be of interest to regulators. Or not the intended target of regulation at all. The fact that resources are too short to understand the detail of every regulation tends to encourage this (potentially ostrich-like) approach.
By Chris Kentouris. EMIR, it’s short for European Market Infrastructure Regulation. It has also become a four-letter word for fund managers struggling to fulfill reporting requirements. About five months after the effective date for fund managers and broker dealers to send details of trades executed on exchange-listed and over-the-counter swap transactions to recognized trade repositories, fund managers are
With the release of ESMA‘s MiFID II Discussion Paper on 22 May, we received confirmation that transaction reporting is set to get 300% bigger. The discussion paper outlines 93 fields to be included in reporting, with the addition of algo, trader and client IDs. For many in the industry, transaction reporting is one of the
JWG analysis. June has been a busy month for all regulatory agencies, and the BCBS is no exception. With 3 consultations, 2 sets of principles and 1 regulatory consistency assessment as well as a 2013/14 annual report published in this month alone, we can see 5 years from the crisis that international standard setting is
JWG analysis. This month the Federal Deposit Insurance Corporation published a proposal amending the Annual Stress Test rule. The Annual Stress Test rule, originally published in October 2012, requires that non-member banks and FDIC insured state-chartered savings associations with total consolidated assets of more than $10 billion conduct annual stress tests. The proposed amendment to
JWG analysis. When we talk to people about MiFID II, they tend to focus on what they need to tell the regulator: transaction reporting, transparency and algorithmic trading often come up {see here for more}. It’s clearly a big deal in terms of firms’ balance sheets and an important part of the regulatory plumbing to
JWG analysis Last week, long after the news of Super Tuesday which reshaped the EU regulatory landscape, Europe made MiFID II, MAR, CSMAD, DGSD and the BRRD law of the land. The final Markets in Financial Instruments Directive (MiFID II) , weighing in at a slim 69% fewer pages thanks to repagination, appears to be
JWG analysis. Depending on whom you listen to, Europe’s trade repositories either popped in for a chat with ESMA, or were hauled in for a stern reprimand last week. Whichever it was, the resulting discussion was pretty explosive. ESMA made themselves very clear; trade repositories must work harder to address low levels of inter-trade repository
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.
As debate rages across the Atlantic today over controlling HFT in Chicago, we’ve been digging into ESMA’s 42 pages on transaction reporting in its MiFID II discussion paper. See here for more background on the 860 questions that need to be answered by 1 August. Years after Dodd-Frank upgraded the surveillance capability of the US,
JWG analysis. MiFID I was all about creating a common set of rules for the single market. Along the way, it asked regulators to track market abuse. They duly set up a system of transaction reporting that all feeds into Paris – 70% of it via the UK. Seven years and millions in fines for
JWG analysis. The continent was rocked by far more than parliamentary elections on 22 May. Early reports from major financial centres confirm the impact from the 844 pages of text released by ESMA on MiFID II / MIFID to be about a 9 on the Richter scale – so high that ESMA’s website gave up
JWG has extracted the following questions from ESMA‘s Consultation Paper on MiFID/MiFIR Technical Advice. ESMA needs to deliver this advice to the European Commission by December 2014 and is therefore subject to a condensed consultation process for this paper. For more on MiFID/MiFIR see here. Q1. Do you agree with the proposed cumulative conditions to be
[accordion] JWG has extracted the following questions from ESMA‘s Discussion Paper on MiFID/MiFIR draft RTS/ITS. This paper will provide the basis for a further consultation paper on the draft RTS/ITS which is expected to be issued in late 2014/early 2015. For more on MiFID/MiFIR see here. Q1: Do you agree that the existing work/standards
JWG analysis. Our jaws hit the floor when it was revealed at our CDMG meeting last week that ESMA’s MiFID II technical standards are expected to be in excess of 800 pages with more than 800 questions to be answered by August 2014. And this is just the start. ESMA’s 2014 work plan has over
JWG analysis. On 15 April the European Parliament formally adopted the Regulation on Central Securities Depositaries (CSDR), a crucial piece of the new EU landscape for securities trading. The impact will be far reaching – and not just for Europe. As firms chart their way through MiFID II and global OTC reform, they will be
JWG analysis. The idea of KYC compliance has traditionally been associated with AML, PEP checks and international sanctions, however the new wave of regulations that is to begin rolling out in 2015 will place a whole new set of pressures on businesses to ‘know their clients’. Rachel Wolcott, writing for Accelus’ Compliance Complete, has highlighted
JWG analysis. While the significant reforms of MiFID II, the BRRD, the SRM and the DGS stole the limelight on ‘Super Tuesday’, other significant legislation also made its way through Parliament. The following reforms highlight Parliament’s move to solidify consumer protection within the wider European market. These reforms, the BAD, PRIIPs KID and UCITS V
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
JWG analysis. On Tuesday, 15 April the European Parliament approved several new reforms to manage banking sector risk and ensure that shareholders, not taxpayers, pick up the tab for the next crisis. Now the political work is done, the MEPs are busy campaigning, and it’s up to the industry and ESAs to work out how
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
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
JWG analysis. While the US HFT debate rages and the FBI launches its investigations, Europe is quietly preparing to set a hard-hitting set of new rules for technical standards. When ESMA begins its consultation around MiFID II / MiFIR tech standards this summer, market participants will need to have their ducks in a row and
JWG analysis. Earlier this month, New York Attorney General (NYAG), Eric Schneiderman, set out his stall with a scathing attack on high frequency trading firms and their practices. Describing HFT firms as ‘parasitic’ and comparing their strategies to “Insider Trading 2 .0”, the NYAG’s statement would have been music to the ears of financial luddites
JWG analysis. Last week, Nasdaq OMX became the first infrastructure provider to be authorised as a Central Counterparty (CCP) under the European Markets Infrastructure Regulation (EMIR). The decision sent waves of mild panic rippling through the OTC markets, putting the focus back on an issue that was already predicted to pose problems for European banks
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
JWG analysis. This week marked the one year anniversary of EMIR’s first implementation deadline. And what a difference a year makes … or does it? This time last year, banks and their customers were busy determining who had passed certain thresholds (determining who would be classified as NFC or NFC+), along with implementing confirmation processes
By Sam Tyfield and JWG. We asked a prominent city lawyer what current EMIR reporting issues could mean if the regulators chose to get nasty. The bottom line: big fines could appear on the cards years down the line. Given where we are with current data quality efforts, this might have an impact on the
JWG analysis. Once MiFIR is enacted over the coming months, there will no doubt be a lot of concern about one little word that threatens to have a serious impact on the commercial operations of many service providers in Europe. That word is ‘reasonable’. By itself, the word reasonable seems harmless. But when used as
JWG co-hosted a webinar earlier this week, along with Banking Technology and the DTCC, examining the recently launched EMIR trade reporting regime. The conversation tackled a range of issues, including challenges faced by industry participants in getting ready for the 12 February launch date, and a look ahead to future milestones in the reporting regime.
JWG analysis. There is a new film making the rounds where the evil ‘Lord Business’ locks up all the master builders in a think-tank and uses them to design his empire. Quite apart from giving JWG analysts a lot to laugh about, it’s a useful theme when exploring what is going on with OTC trade
JWG analysis. If you’re reading this post, then it’s more than likely you are in one of the many job roles that are impacted by financial regulation. Whether you are directly involved as COO or a legal, compliance, governance or risk officer, or indirectly involved in an operational, IT or business capacity, it’s clear that
JWG analysis. “When a tree falls in the woods, does it make a noise?” While some may find the question trivial, it has provided much food for thought for philosophers since it was first raised in the early 1700s. The answer to the question relies on one’s assumptions on whether observation is a necessary condition