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Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the September briefing - the first of a series on MiFID II. For more information visit www.bovill.com. Further information on the event is below: MiFID brought major regulatory change to investment firms back in 2007. But technological strides and market developments since the financial crisis are now exposing weaknesses in the directive. MiFID II is a complete rebuild – aiming to close the gaps in the regulatory framework and introduce a ‘Mark 2’. Strong enough to protect the investment industry whatever the future holds, Mark 2 will also help achieve all of MiFID’s original aims by bolstering investor confidence. At over 200 pages, MiFID II is longer, broader and more granular than MiFID I. It increases regulatory requirements, may well bring new firms into its scope, and will require changes to the way some investment firms currently work. The first in a series of Bovill briefings on different elements of MiFID II, this introductory session provides: • a general overview of the directive • detailed timelines • the steps you need to start taking now. This briefing is relevant for all compliance officers of firms that undertake investment business in UK and Europe including those firms that are currently exempted from MiFID I.
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Combining regulatory tools
4
Recast MiFID
MiFIR MiFID II
Understanding the levels of detail
5
• Framework Directive and Regulation
Level 1 – Framework Legislation
• Delegated and Implementing Acts
Level 2 – Implementing Measures
• Implementing Technical Standards and Regulatory Technical Standards
Level 2.5 – Technical Standards
• ESMA issue non-binding guidance on the meaning of the Levels 1 and 2
• National regulators comply or explain
Level 3 – Regulatory convergence
• EC takes enforcement action for any failure to implement or inconsistent implementation.
Level 4 – Enforcement of Directive
MiFID II timeline
6
2014 2015 2016 2017
Legis
lation
ESMA Level Two
Advice to EC
Due 03/01/15
Level One entry
into force
02/07/14
Level Two
Published in OJ
Due 03/01/16
MiFID II applies
03/01/17
RTS to EC
Due 03/07/15
National
Transposition
Due 03/07/16
ITS to EC
Due 03/01/16
A first glance at the implications
7
MiFID (Directive)
Scope – Exemptions and Definitions
Authorisation
Corporate Governance
Conflicts of Interest
Inducements and Commissions
Client Categorisation
Product Governance
Best Execution
Algorithmic Trading
Passporting
Third Country Firms – Branch
MiFIR (Regulation)
Third Country Firms – Cross Border
Pre and Post Trade Transparency
Trading Obligations
Consolidated Tape
Transaction Reporting
Product Intervention
Approaching your project line by line
11
Helping you tackle MiFID II
12
Briefing series
• Start 2015
• Based on draft Level 2
• Topic by topic
Client toolkit
• Topic by topic
• Level 1 and 2
• Main changes
• Next steps
There is a lot of content in MiFID II and a lot more to come
in Level 2.
Don’t wait for FCA rules or even the final EU legislation
START PLANNING FOR MIFID II NOW
Final thoughts
13
• read
• ascertain gaps
• develop solutions
• identify opportunities
Analysis and
planning
• change
• test
• train
• client contact
Implement
Yo
ur
pro
ject
