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


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


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,


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. Last month (20 June), the Hong Kong Monetary Authority issued a new Supervisory Policy Manual (SPM) on the topic of recovery planning (Module RE-1: Recovery Planning) following a consultation with Hong Kong’s two industry associations. This follows the Financial Stability Board’s push to implement standards in the area of recovery and resolutions plans


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


JWG analysis. Last week the Prudential Regulation Authority (PRA) released several key documents including its annual Policy Statement amending certain aspects of the PRA Rulebook. These policy changes are sure to have an impact across all firms that come under the PRA’s regulatory jurisdiction. The PRA has: Amended eight of its Fundamental Rules which replaced its


JWG analysis. In our previous piece we spelt out the breadth and depth of the regulatory onslaught in the context of MiFID II.  Here, we unveil how RegDelta can help you redefine the battlefield. What is RegDelta? RegDelta gives firms the ability to control global regulatory challenges.  RegDelta is a financial services regulatory data management


Battle weary? RegDelta is on its way!

JWG analysis. For the past decade we have been making sense of the changes regulators want to make … and it’s not been easy.  JWG has worked with over 100 financial institutions, dozens of trade associations and regulators in several countries to mirror the detailed compliance requirements specified by the regulatory agenda to help define


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


Video: Regulatory reform – 2014 helicopter view. Regulation is coming thick and fast.  Seventy thousand pages a year fast! Dealing with this deluge with a page-by-page, regulation-by-regulation approach is becoming impossible as the G20 commitments become spread across many rulebooks.  This means that firms trying to tackle the changes one-by-one will end up with sky-high implementation


AMLD IV adds fuel to KYC utility model

JWG analysis. The European Parliament recently published (here) the latest amended text of the proposed 4th Anti-Money Laundering Directive (AMLD IV), which includes measures to help simplify the way firms conduct KYC today, and adds weight to the KYC utility business model by requiring the industry to maintain accurate and timely data on beneficial ownership.


How many types of risk are there to a financial institution?  In recent years the list has grown from patently quantifiable risks – market, credit, liquidity – into more nuanced forms of risk, such as conduct risk and systemic risk.  However, increasingly ambitious regulation and certain key legal decisions have brought with them a new


In May, the CFTC’s Bart Chilton characterised regulatory cost benefit analyses a “sword of Damocles” calling out for more qualitative data. Since then, multiple no-action letters and a court case against the SEC have shown that there are deep-seated issues with CBAs that regulators are having trouble keeping below the surface. For the SEC and


HFT: On the brink of definitive new controls?

Thanks to technological hiccup after technological hiccup, High Frequency Trading (HFT) remains a permanent fixture in the financial press. With each blip, regulators and politicians promise to regulate HFT, but how they are going to put effective controls in place is still an open question. Despite the noise, the issues with HFT remain the same.