Jump to content
  • Eva Keogan
    Eva Keogan

    Sign in to follow this  

    MiFID II … are we there yet?

    The Markets in Financial Instruments Directive (MiFID II) is regarded as one of the most significant and far reaching regulatory initiatives undertaken since the economic crisis of 2008 and the last ten years.

     

    In 2009, when the G20 committed to manage the risk associated with OTC derivatives trades, the European response was European Market Infrastructure Regulation “EMIR” (into effect as of August 16, 2012) and MiFID II. Eight years on, it’s pretty reasonable to ask – are we there yet?

     

    MiFID II was originally scheduled to come into place as off January 2017. Due to concerns over the tight timeframe to implement the directive, its complexity and the necessity to build IT infrastructure systems, the implementation date was delayed a further year to January 3, 2018. Where previous regulatory changes often had a phase in period, MiFID II is a kind of ‘big bang’.

     

    MiFID II is going to impact the overall business. From transaction reporting, product governance, general inducement rule and unbundling of research to best execution and market infrastructure, its aim is to reshape the European capital markets. The impact will be felt way beyond Europe. For example, third country firms providing investment services or activities in the EU will have to submit transaction reports to the regulator which authorised them.

     

    What are some of the key challenges companies are and have been facing when implementing MiFID II?

     

    Data management

    The financial services industry is known for its legacy systems and challenges it faces in handling the multitude of data needed to comply with the requirements of MiFID II. Fit for purpose IT systems are easier said than done. This very thing has already caused significant headaches for many companies even for what is considered to be the “simplest” increase of client reporting with now 65 data fields instead of previously 29. It is not only the increase of data which is a challenge, but equally the correctness of data when extrapolated from legacy systems or in general.

     

    Adequate oversight and governance

    According to Don Scott, Director, KPMG Regulatory Advisory Services in the recently published report ‘MiFID II The Time To Act Is Now’, “industry practice will continue to change until a market standard has evolved”.

     

    But MiFID II has far reaching oversight and governance changes. Within the product management cycle, manufacturers and distributors become both responsible for ensuring that investment products are distributed to a target market of end clients. This does not stop with the design, development and launch of a product but needs continuous oversight throughout the life cycle of a product. The responsibility lies with the manufacturer as well as the distributor to prove products are and have been distributed to the target market. Equally they need to prove clients remain fitting the target audience and this is achieved through ongoing verification of the suitability of the clients profile.

     

    Equally, the responsibility of companies for showing they have adhered to “best execution” of trades has changed from taking “reasonable steps“ to “all sufficient steps”. This previously applied to equity asset classes and has now been extended to non-equity asset classes combined with a significant reporting obligation on where these trades have been executed. Clearly this will bring significant challenges for companies to show and “evidence” their compliance, not on a trade by trade basis, but through a robust set up of processes, procedures and governance over it. A 2016 asset management market study by the FCA has highlighted that investment managers are still failing to ensure effective oversight of best execution.

     

    Accountability and conduct

    This is most felt through the inducement rule and the unbundling of investment research and execution. Some EU countries already banned commission payments for retail clients (UK, Retail Distribution Review) with MiFID II making this more generally prohibited across the EU to avoid conflicts of interest.

     

    The unbundling of investment research and execution aligns very much with the rule of “best execution” of trades and sets clear rules for when investment firms use “broker commission” to pay for research. Ultimately it is up to the investment firm to show that the research which is being paid for from broker commission is to the benefit of the investor.

     

    Transparency

    Creating transparency of the overall financial market aims to better understand, from a macro point of view, the risk(s) that investment markets in general pose to the stability of the financial markets and as such better protect investors. Reporting requirements are increased and broadened significantly and the capital markets playing field is made more balanced by bringing more asset classes and instruments within a regulated market environment as well as tightening the rules around it.

     

    So are we there yet?

    While this weighty agenda has been with us now for some time, the implementation date of January 3, 2018 is clearly not the end date of MiFID II.

     

    The rules will continue to be interpreted and understood and therefore develop and evolve.  Looking back at MiFID I – which came in to play in April 30, 2004 and into national law as of January 31, 2007 – it’s fair to say there have been ongoing developments ever since. MiFID II and its outcomes will therefore very likely also impact companies and markets alike and remain on our collective agendas over the next five to ten years.



    Sign in to follow this  

    Share this  

    Member Feedback



    Recommended Comments

    There are no comments to display.

    Become a member to read more and join the discussion

    Members can read and contribute to discussions

    Apply

    Register now for free access.

    Create your account

    Sign in

    Already a member? Sign in here.

    Sign In Now

  • Our picks

    • FSTP LLP in partnership with AlgoMe invite you to a lunchtime round table discussion on the most pressing issues in today’s industry; digital skills shortage and the apprenticeship levy
       
      Introducing your hosts:
      FSTP LLP, a Main Provider for Apprenticeships offering Financial Services, Leadership and Management Apprenticeships, will be on hand to share insights and experience AlgoMe, the community for the Investment Management industry, connecting professionals from Asset Managers, Wealth Managers and FinTechs with their wider industry ecosystem will be on hand to discuss skills and transformation in the industry  
      The event:
      12.30 - 12.50
      Your co-hosts Rob Carter and Andy Milner, AlgoMe will give an overview of demand for retraining and tech skills, based on the latest AlgoMe report; The Disrupted Career: FinTech, Innovation and The Future Of Careers In Investment Management Followed by Philippa Grocott and Nicola Spennati from FSTP LLP, will give an overview of opportunities for using the apprenticeship levy and how to do so effectively within the industry sector 12.50 – 14.00 Group discussion over lunch
       
      Attendance is limited and on a first come first serve basis. Please contact andy.milner@algome.com if you would like to attend.
        • Like
      • 0 replies
    • The Disrupted Career
       
      Welcome To The AlgoMe Report On FinTech, Innovation And The Future Of Careers In Investment Management
       
      This report aims to address key questions that are important to everyone working in or looking to join the Investment Management Industry.
       
      How significant will the impact of FinTech be on career paths? How likely is my current role to be affected? Where are the opportunities in this disruption? How can I best position myself for future success?  
      We asked a panel of Investment Industry professionals their views.
       
      The full report is available for download to all AlgoMe Community members. Not already joined? Becoming a member takes less than a minute.
        • Like
      • 0 replies
    • With the decorations up, the last order date for Amazon nigh and most of us looking forward to at least a few days break, it’s always a good time to take stock of what’s been achieved over the last 12 months.
       
      For AlgoMe this has been another exciting year.
       
      January started in style with the launch of the AlgoMe Careers mobile app – giving professionals the opportunity to find their next career opportunity on the move.
       
      Then in July we released our Industry Pulse Report – a check on what the industry was thinking about key topics such as Brexit, Pay Gap Reporting, MiFiD II and GDPR. Unfortunately it seems that the uncertainty that the industry was feeling due to Brexit is unlikely to have receded in the intervening period, but it’s good to see progress starting to be made in other areas such as gender and diversity.
       
      In September we launched AlgoMe Community – a place for the Investment / Asset Management industry to come together, providing professionals with ways to grow their knowledge, profile and network. We’d like to say a big thank you to all of the members that have joined and contributed and look forward to continuing growth in 2019.
       
      In November AlgoMe joined the Investment Association, becoming a Fintech member and working closely with Velocity, the Association’s new Fintech accelerator. This is a really exciting initiative and we’re looking forward to doing more with Velocity in the near future.
       
      We also launched our Mentoring matching service in November – designed to help AlgoMe Community members connect with the best individuals within the community to help them to reach their career goals using a simple but intelligent process. If you haven’t already signed up to be a mentor or a mentee, please do spend 5 minutes now and tick off a New Year’s Resolution early.
       
      As we go into the end of the year, we have also launched our survey on Investment Management, Fintech and the future of careers. The impact of Fintech on the industry is going to accelerate rapidly in 2019, but what has been less well documented is the impact on individuals, their careers and the skills they’ll need to succeed in a more digitised environment. We really value the input of our community members, so please spend a couple of minutes filling out the survey and we’ll make sure you’re the first to hear the results early next year.
       
      From me and the AlgoMe team, I wish you all a very happy holiday season and look forward to another year of exciting announcements and change in 2019.
       
      Rob
       
        • Like
      • 0 replies
    • I have always struggled to see a fair reason why employers should be allowed to ask about a potential hire’s current remuneration, other than to give them an advantage in pay negotiations.
      It’s something which can only exacerbate existing pay inequalities and  it’s abolishment can surely only be a positive thing.
      Here the Guardian argues specifically about its impact with regards to the gender pay gap:
      https://www.theguardian.com/commentisfree/2018/aug/23/gender-pay-gap-current-salary-question
      I believe this has already been outlawed in some US states?
      @Jonathan Max - would be interesting to hear the view from HR. 
      • 10 replies
    • The Investment Association recently gave the industry a boost when it announced the launch of Velocity, its FinTech accelerator.  Designed to identify, develop and accelerate best in class firms with innovative solutions, Velocity will champion and facilitate the wider adoption of technology across the industry.
       
      And AlgoMe will be involved in this too, which is why I’m excited to announce we are now a member organisation of the Investment Association as an official FinTech member and have been named a "company to watch" by Velocity.
       
      Challenging Times
      The Investment Management industry faces major challenges and opportunities from forces such as digital technology, pressure on fees and increased regulation, while at the same time there are widespread changes in the workforce and their expectations.
       
      To date, Investment Management has both been fairly insulated from the challenges posed by agile FinTech competitors, but also distant from the opportunities offered by the new technologies and ways of thinking that such companies bring.
       
      Bringing FinTech closer
      Velocity is a fantastic step towards accelerating the adoption of FinTech. It has received support and endorsements from both inside and outside the industry, including from the Chancellor of the Exchequer, Phillip Hammond, who was enthusiastic about the initiative at a recent City event.
       
      To drive change and innovation, the industry needs to connect across different disciplines and areas of expertise, driving new ways of thinking and fostering cultural change.
       
      Without the benefit of emerging FinTechs and their external expertise, it will be hard for incumbents to harness the benefits of emerging technologies such as Straight Through deal Processing (STP), Distributed Ledger Technology (DLT), and Artificial Intelligence (AI) in areas such as risk and compliance, securities trading and investment decision making.
       
      Our Mission
      AlgoMe's mission is to connect the Investment Management industry and empower professionals to manage their careers. Our new product, AlgoMe Community, is placed to become the hub for the discussion between FinTechs and the companies and professionals in the wider Investment Management ecosystem.
       
      Join AlgoMe Community today
       
      AlgoMe Community - community.algome.com
        • Like
      • 0 replies
  • Related Content

    • Rob Carter
      By Rob Carter
      Brexit, MiFID II, GDPR, Gender Pay Gap and Diversity are the themes we consider top of mind currently which is why we’ve created the Summer 2018 AlgoMe Industry Pulse Report.
       
      We wanted to get under the skin of some of these key events and burning issues for 2018. In doing so, we revealed some very interesting results and statistics.
       
      Given a choice of 7 cities, Dublin, Paris and Amsterdam are the top three choices for Asset Managers, Fintech and Financial Services employees to relocate to following Brexit. While 54% would not consider moving as a result of Brexit.
       
      When it comes to regulation; we are not surprised to find MiFID II and GDPR will affect over 60% of the roles in the industry.
      Positively, 59% believe Gender Pay Gap Reporting will improve the career progression of women.
       
      Please read the report for the full information and do get in touch if you would like to know more about your industry workforce.
       
      Rob Carter, CEO, AlgoMe
    • Julia Kirkland
      By Julia Kirkland
      Guest blog from Julia Kirkland, Senior Partner at FSTP
      If you don’t know already, which of course you do, the Markets in Financial Instruments Directive (MiFID) is EU legislation which first came into effect in 2007. It was created to regulate firms providing services to their clients which are linked to ‘financial instruments’, these being shares, bonds, units in collective investment schemes and derivatives. In addition, it covers the venues where those ‘financial instruments’ are traded.
       
      Fast forward 10 years or so and we have an updated version – MiFID II. This includes the revised MiFID and a new Markets in Financial Instruments Regulation (MiFIR). January 3, 2018 is the day MiFID II must be implemented across Europe.
       
      Now we’re on the cusp of this deadline, the thorny and sensitive topic of Knowledge and Competence (K&C) is bubbling up as a major concern across the industry.  We’ve spoken with numerous firms in both the Asset Management and Wealth Management sectors and they have one thing in common; they’re all grappling with the assessment of competence of information providers.
       
      Who is in scope? 
      In Asset Management, this may cover a wide range of roles from sales teams, client services, broker servicing staff to Portfolio Managers (the really sensitive aspect of K&C). Managers may struggle with the fact they must tell a Portfolio Manager of 20 years plus who hasn’t got a formal qualification, they need to be assessed as competent and in a very short timeframe too.
       
      In Wealth, the scope may cover desk assistants, team secretaries and portfolio assistants who may all be in direct contact with clients, giving them information about prices, valuations, charges and providing generic market or sector views. Additionally, research teams who might attend meetings with clients to provide market, sector or stock views on a non-advised basis may fall under this too. Most of the firms we are speaking to are including research teams. Most of the above staff members have never been included in formal K&C Schemes before but this has changed.
       
      What happens in 2018?
      As it stands, information providers not assessed by January 3 will need to be supervised in their activities and oversight of any client interaction must be in place. If you’re not prepared, January 2018 is fast approaching and maybe it’s time to look outside your company for third party support and assistance.
       
      Our guest blogger Julia Kirkland, is Senior Partner, FSTP
      FSTP is a training solution provider with expertise in MiFID II and the company also runs workshops to cover Wealth and Asset Management to meet the ESMA requirements and provides advanced K&C assessments for more seasoned, professional staff.
    • AlgoMe
      By AlgoMe
      Understanding your state of readiness for SMCR extension - City HR
      CITY-HR.CO.UK Assessing your readiness for the SMCR extension Aimed at firms embarking on SMCR, or those in scope who would like latest thinking, this programme will: Provide an SMCR overview with expert insight direct...  
    • Rob Carter
      By Rob Carter
      The UK is a hotbed of fintech activity, and it has not escaped the attention of investors worldwide. so what can we expect in 2018?
       
      Last year, almost £3bn of venture capital found its way in to the UK’s tech sector, a record high and nearly double the figure for 2016. British fintech firms attracted almost four times more funding in 2017 than Germany, and more than France, Ireland and Sweden put together. This year promises to be even bigger, but what are the exciting developments driving those investment flows?
       
      Here’s what to expect in 2018 across five key areas we’ve identified:
       
      Open Banking
      One of the most exciting developments to land in the UK financial sector is Open Banking. Under these new rules, which came in to force in January this year, banks must share their customers’ financial data with other FCA-authorised institutions, if customers request them to. This includes bank and credit card transactions and information about spending habits, for example. The aim is to improve competition in the marketplace and ultimately help consumers get a better deal. It should also foster much greater innovation, as new alliances are forged between traditional financial services firms and fintech startups. This is already starting to happen – First Direct has partnered with fintech firm Bud, Barclays is working with Flux, and NatWest has teamed up with FreeAgent. Banks are working hard in-house too: HSBC, for example, has launched a beta app which will allow customers to see all their accounts on one screen, even those from rival providers. Expect more innovation and unlikely partnerships in the banking sector this year.
       
      Wealthtech
      Wealthtech refers to the specific type of fintech which is used to solve problems and improve user experience in the wealth management and investing world. The definition includes robo-advisers like Nutmeg and Wealthify, as well as micro-investment services and digital brokers. They focus on the under-served mass market of people who would like to invest but only have small savings pots to play with, or who perhaps can’t afford financial advice or wouldn’t be economically viable clients for traditional financial advisers to take on. Robo-advice and micro-investing tools help to democratise investing and make it accessible to a much wider consumer base. Although some of these companies may take time to become profitable, the assets they manage are set to grow rapidly. Deloitte estimates the $2 billion in assets under automated management globally today may grow to as much as $7 trillion by the year 2025.
       
      Cryptocurrencies
      So strong has been the hype around cryptocurrencies that some listed companies in totally unrelated sectors have linked themselves to the space by changing their names or the focus of their businesses. Just adding the word ‘blockchain’ in somewhere has proven enough to send their share prices soaring (see Long Island Iced Tea Corp, now called Long Blockchain). But there may already be signs that the bubble could burst – highly volatile Bitcoin has fallen a long way from its lofty highs, and there is a regulatory threat from financial watchdogs globally following a crackdown by South Korea. There could be interesting developments to come in cryptocurrencies this year as companies navigate the new landscape.
       
      Regtech
      Regtech refers to the use of technology to help financial services firms better comply with regulation. It’s been dubbed ‘the new fintech’ and it is a fast-growing area. Regtech businesses help other firms to meeting their reporting and compliance obligations, monitor transactions, and manage risk. Firms like Funds-Axis, DueDil, and Silverfinch are part of this growing movement. Deloitte says: “RegTech has a very bright future, with a huge amount of opportunity for those developing this type of technology to automate and enable the world of regulatory assessment and control management, bringing clarity and control to an area of the business that is so incredibly important, but so often cumbersome and time-consuming.” With the Financial Services industry under more regulatory pressure than ever and drowning in legislation, Regtech should be a fascinating area to watch.
       
      Artificial intelligence
      When you think of AI, you might think of chatbots being used to replace customer service people, or voice command technology like Amazon Alexa. But the applications of AI in fintech go much further. It can be used to spot suspicious transactions and cybersecurity threats, or predict consumer behaviour and make more accurate predictions based on these insights – for example, whether someone will be a future credit risk. Machine learning can be used to create a customised investment portfolio based on someone’s personal interests and preferences, updating it as their preferences change over time. The possibilities are endless, and who knows how the FS industry could change when AI reaches its full potential?
       
      As always, only time will tell when it comes to forecasting the future but one thing is sure, the UK fintech market is thriving now and will continue do so for a long time.
    • Rob Carter
      By Rob Carter
      It’s 2017 and technology surrounds us as never before. Asset Managers are investing a lot of time and money to get to grips with both FinTech and the new kid on the block RegTech. At AlgoMe we’re fascinated by the way technology is changing the world of work and skills. We’ve put together some key technology themes which we think will be big this year and what to watch out for too.
       
      Big data analytics
      Big data is creating a buzz across the business world and is one of the most important challenges and opportunities facing financial businesses today. IDC, the global market research, analysis and advisory firm, predicts that the big data and business analytics market will grow from $130 billion to $203 billion by 2020. The problem is, firms collect swathes of customer data, but without the tools to mine these so-called ‘data lakes’ correctly, they are not getting analytics they can develop actionable insight from. Done correctly, it’s immensely valuable and more than just analysing customer behaviour – analytics can be used to predict the regulatory and operational risks the firm itself could face. For example, using technology to analyse the root cause of any previous regulatory breaches could prevent the same mistakes from recurring in future. The FCA has acknowledged that it too could use big data analytics to reduce the reporting burden on firms. Last year it launched the Regulatory Sandbox to help firms innovate and this has already produced some interesting results in the world of banking technology. Some companies are launching Data Analytics as a Service for the Asset Management industry and the knock on effect will be a demand for professionals with new skill sets to embrace this new opportunity.
       
      Machine learning
      No doubt you’ve probably heard of robo-advice, but there are also other ways that machine learning can be applied in financial services. Possibly the most disruptive of technologies to break into the financial services space, you should expect to hear more about machine learning and robo-advice (with a soupçon of AI thrown in) this year.
       
      Just last month LendingRobot, a specialist online investment-management service or so-called “robo-advisor,” announced its launch of a hedge fund which is administered without human intervention. Silicon Valley has also woken up to the opportunities and companies like Sentient Technologies will be grabbing headlines this year.
       
      P2P platforms and other lenders use algorithms to make lending decisions and predict bad loans. There are also firms which use machine learning to scour social media and news sites for trends to give their clients signals to trade on. The FCA has noted that because machine learning can automatically refine processes in reaction to user input, they could replace some of the complex, high volume tasks firm need to perform to remain compliant.
       
      For now, there’s no need to grab your coat and head for the door; technology hasn’t taken over quite yet! However, understanding how these trends will impact your business area will be essential in the coming months. 
       
      Cybersecurity and fraud prevention
      With MiFID II a big headline for 2017, the need to adopt new technology to support compliance has never been more apparent. The regulatory burden for Asset Managers can be lightened by RegTech as it can be used effectively to monitor transactions, trades and communication in real time, all the time. By correlating information gathered from different sources, powerful calculation engines can highlight errors, gaps and current trends in financial crime to help firms shore up their defences. With financial institutions a regular target for hi-tech cyber criminals, fighting fire with fire has never been more important. We expect this area to become more central to the industry in the short term.
       
      Automation
      The Asset Management industry suffers no shortage of data but it is faced with management and automation challenges. Organisations are increasingly looking towards technology in their operating models to simplify administration and, where possible, to reduce the costs associated with fund managers doing things manually. It’s a great way to reduce the pressures on margins and increase overall performance.
       
      In 2017, you can expect to see a lot more companies like CG Asset Management adopt automation. Performance reporting, regulatory reporting, investor communications and fund expense management are key pressure points for companies struggling to move away from the legacy systems they have always used or for those who have bought pick and mix technologies that will not integrate seamlessly.
       
      This is a major investment for an organisation and a positive direction for the wider industry to move towards – it will also mean bringing your teams up to speed with new platforms and technologies very swiftly.
Debug info for admin:
appcms
modulepages
controllerpage
topics/forum ID28
page ID
PHP user agentCCBot/2.0 (https://commoncrawl.org/faq/)
×

We use cookies to give you the best possible experience. If you continue, we’ll assume you are happy with this. For further information, see our Privacy Policy.