No MiFID II concept causes more nose-wrinkling and brow-furrowing than the horribly named systematic internaliser: ‘SI’ to save time and seven syllables. Under MiFID, the SI concept wasn’t well understood but there were only around a dozen SIs in the whole of the EU (most in the UK). Under MiFID II, however, SIs have been given a starring role and over 150 are listed by ESMA. So if you're wondering what the heck an SI is, here’s the low down.
In line with the UK Government's earlier statement that "as we get nearer to March 2019, preparations for a ‘no deal’ scenario would have to be accelerated" (although, it stresses, "such an acceleration does not reflect an increased likelihood of a ‘no deal’ outcome"), October saw the publication of a number of important documents providing more detail on what the rules look like for a no deal scenario. We now have a draft UK law for MiFIR, proposal for a temporary transitional power to be exercised by UK regulators, and two hefty FCA consultation papers. This article covers recent developments and provides useful links.
Making laws which apply to half a billion people and need buy-in from 28 countries, plus a European Parliament, means a complex framework so whilst EU rule-making is second nature to those involved in the process such as lawyers and policy wonks, for everyone else it's a bit of a labyrinth. I know: I’ve been in it and explained it to 'lay' audiences - eyes widen, jaws sag, four letter versions of “seriously?” are muttered. On the plus side, all EU legislation is made this way (for the moment) so once you know the process it stands you in good stead. This article whips through what the European Commission, Parliament and Council are and how EU law is made.
MiFID II multiplies the amount of data that must be collected, reported, published and transferred exponentially. Every time you breathe, you're probably inhaling a few hundred pieces of data floating round in the ether. And this wasn't done lightly: new data firms and identifiers were created, debated and continue to make the news. So if you want a recap on what's an ISIN and an LEI, what does DRSP stand for, and what's the difference between an ARM, APA and a CTP, this covers you.
There are a lot of financial trade associations out there, doing sterling work for their members. Who are they, what's their niche and what do those acronyms stand for? This page pulls the info together for you.
Pre and post trade transparency rules were given a big overhaul under MiFID II, especially for non-equities (bonds, derivatives) and it’s likely to continue being an area of focus as regulators watch the impact of these rules on the markets. But before getting into the nitty gritty of double volume cap, waivers, deferrals and all the rest, the first question is do you know what pre and post trade transparency is? (And if you don’t, you’re not alone). Read on…
In Showbiz you know you’ve made it when people know you by your first name (think Elvis, Madonna, Rihanna). In finance, it’s different: be you a firm, a financial instrument, a regulator, a regulation or trade association, you’re really looking to be known by a short jumble of letters – your acronym. This is the first in a series of posts called “Acronyms ahoy” to help you navigate through these letter strewn waters. There really is an embarrassment of riches in the financial sector but for the inaugural post there can only be one choice – MiFID II, and there are so many of them, this is a three-parter.
It's rumoured there are over a million paragraphs of MiFID II rules and you can forget thinking you might find them neatly filed in one place: different parts are written by different authorities, published on different websites. Plus MiFID II is EU law and whilst EU rule-making may be second nature to those involved in the process, it’s as opaque as the Enigma code to most people. But it's not a problem: to make this as painless as possible for you, here are the links to the rules in one place plus the bare-bone-notes on what you need to know to understand where they fit into EU rule-making jigsaw.
Financial services regulatory consultancy, specialising in MiFID II: resources, training & tips