MiFID II: What are you missing?
A post-implementation checkpoint for asset managers:
One month after implementation, we can’t ignore the effects of MiFID II. After years of development, drafting, deliberation, debate, delay, denial and deferment, the directive is finally, for the most part, in effect.
Buy-side firms now face new challenges. Firstly, implementing those residual requirements that were not enacted on January 3, 2018. And secondly, ensuring that what has already been implemented achieves full compliance.
But the scope and complexity of the requirements have meant that industry consensus is still being formed in some areas. Many firms have implemented arrangements based on assumptions and understandings which will need to remain under review. Mistakes made during implementation could result in non-compliance and costly remediation if not identified promptly. MiFID II is a case in point of a large, time-constrained project with unclear and poorly defined requirements based on a shifting legislative base.
Read our latest article, which identifies potential problem areas for any MiFID II post-implementation project, and provides a list of questions that firms should be asking themselves to ensure full compliance has been achieved across a range of functions, including:
- Transaction Reporting.
- Post-Trade Transparency Reporting.
- Best Execution.
- Payment for Research.
- Record Keeping (Including Communications Recording).
- Management Body Responsibilities.
Click here to learn more about our MiFID II post-implementation services.