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Markets and Securities Services | Issue 46
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It is for this reason that we felt it would be
invaluable for firms to be able to gain an
insight into where their peers stand on the
strategic thinking and implementation of
a wide range of requirements under this
amended directive and regulation.
Having surveyed a wide range of asset
management firms, we have provided an
overview of the questions and responses
received below. The results are displayed in
this way to anonymise the identities of firms
that participated in the survey.
How prepared are you for the MiFID II/MiFIR
go-live date in 2018?
Some firms started to address their MiFID II/
MiFIR implementation projects a while ago,
undertaking initial gap analysis or impact
assessments and very quickly realising the
magnitude and complexity of the task ahead.
Now that we know that there is a 1-year
extension to the original deadline — from 2017
to 2018 — we thought it would be interesting
to ask asset managers where they sit in terms
of their implementation planning and the kind
of strategic decisions that they have needed
to make, or may still need to make, for their
businesses.
Appropriateness regime
Under MiFID II, the range of products
deemed too complex, and subject to the
appropriateness regime, will be widened.
Industry initially feared that non-UCITS
retail schemes (or equivalent) would
automatically fall into the category of
complex, requiring assessment of an
investor’s knowledge and experience.
The Delegated Regulation (C (2016) 2398
final), published on 25 April 2016, appears
to provide a degree of flexibility so that
non-UCITS retail schemes (or equivalent)
can be assessed on a case-by-case basis.
THE ASSET MANAGEMENT
SURVEY: MiFID II AND MiFIR
MiFID II and its partner MiFIR is a wide-ranging piece of legislation and,
depending on your business model, could affect a broad range of your firm’s
functions — from trading, transaction reporting and client services to IT
and HR systems. It will radically change the regulation of EU securities and
derivatives markets, and has the potential to have a significant impact on the
investment management industry.