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. The trading capacity under which the firm has conducted business is a key factor to establish when selecting a best fit example from the guidance. Once published, this guidance will contribute significantly to the much needed detail for system specifications around one of the biggest pieces of MiFID II.

As a result of comments received from the consultation, ideally ESMA should add some more examples to help further clarify different scenarios – e.g. where multiple client funds are involved or where trading off book is subject to the rules of a venue. So whilst ESMA and the Commission are pushing each other ever closer to acceptance of the Level 2 details in the interest of a timely implementation, tension is growing.

Success is somewhat dependant on current proposed amendments playing out as soon as possible, and a speedy endorsement of the RTS being received. Even with a year’s delay and a finish line of January 2018, time is of the essence.

Leave A Comment

Copyright © 2019 Fidessa Group Holdings Limited. All rights reserved.

The information contained within this website is provided for informational purposes only. Fidessa will use reasonable care to ensure that information is accurate at the time it is made available, and for the duration that it remains on the site. The information may be changed by Fidessa at any time without notice. We also reserve the right to close the website at any time. No representation or warranty, expressed or implied, is given on behalf of Fidessa or any of its respective directors, employees, agents, or advisers as to the accuracy or completeness of the information or opinions contained herein or its suitability for any purpose and, save in the case of fraud, all liability for direct, indirect, special, consequential or other loss or damages of whatever kind that may arise from use of the website is hereby excluded to the fullest extent permitted by law. Any decisions you make based on the information in this website are your sole responsibility and information on the website should not be relied upon in connection with any investment decision.

The copyright of this website belongs to Fidessa. All other intellectual property rights are reserved.

Reproduction or redistribution of this information is prohibited except with written permission from Fidessa.