 Post-MiFID Implementation Reviews
The Markets in Financial Instruments Directive (MiFID) affected everything from business process and practice to client relationship management and IT structures, but has been implemented unevenly across Europe, with some Member States still non-compliant.
The changes, whilst mandatory, created windows of strategic opportunity: however, much of the detail remained unclear up to and past the November 2007 implementation date, forcing firms to make their own interpretations or fail to implement fully.
The short implementation period created material stresses and uncertainties, and a significant amount of rushed work, heightening many firms’ operational risk. A number are still behind the curve in respect of training, outsourcing, and recordkeeping.
The FSA commences its own review of firms’ implementations, standards and processes in Q2, 2008. The challenges were significantly different for retail and wholesale firms and for domestic and branched firms. The dust has yet to settle, and implementation changes are still in process, for firms, markets and Competent Authorities across Europe.
Against this backdrop, many firms are looking for assurance ahead of the forthcoming regulatory review that their own implementation has reached the required standards, and that strategic opportunities were both recognised and taken.
Based on the experience of directly managing the regulatory impact of MiFID for a top 10 global bank across five business lines in eighteen EEA countries, whilst working on the MiFID Connect Practitioner and IT Committees, we offer unparalleled practical subject matter expertise and depth of business understanding.
We can help you by:
- Assessing the validity, simplicity and appropriateness of the firm’s policies, from risk management to order handling and execution and conflict management;
- Validating firms’ interpretations and processes implemented to meet them;
- Identifying any material gaps in the implementation programme and consequent management reporting;
- Reviewing the adequacy and appropriateness of the firm’s new recordkeeping structures;
- Providing practical rather than theoretical training, based on your own business model, adopted policies and product base;
- Identifying strategic opportunities that may have been missed.
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