So much to do, so little time

This week’s closing date for the ESMA consultation, which sets out amongst other things a non-exhaustive list of transaction reporting examples as Level 3 guidance, is a keen reminder of just how much there is to be done for MiFID II. This hefty document, published in December last year, is a crucial step that will allow the implementation to pick up some pace over the coming months. ESMA’s intention is to help firms navigate the rules in RTS 22 and construct a valid report.... Read More

A brief history of on/off-exchange

Hailed by legislators as the new framework to close loopholes, MiFID II will see OTC trading face new restrictions, most importantly in the form of the Systematic Internaliser (SI) and the new trading obligations. As the fog slowly lifts, it’s becoming apparent that these new restrictions could impact market structure in surprising ways. A more detailed analysis shows that ETFs, ADRs and other similar financial instruments will face comparable requirements to equity shares.... Read More

MiFID II – back to square one

A proposed new law is currently making its way through the Brussels/Strasbourg law-making factory to delay the introduction of MiFID II. There is little doubt that the industry will breathe a sigh of relief when the delay is finally confirmed. However, the proposed new law has also encouraged legislators to consider further changes to the MiFID II Level 1 texts (amendments 1-3 and amendment 2), which risks undoing a lot the of political compromises it took to get it passed the... Read More

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