The Futures Industry Association has published a compliance brief on the impact of MiFID II/MiFIR on US futures commissions merchants (FCMs).

The brief focuses on compliance obligations for US FCMs and their non-EU clients when MiFID II/MiFIR take effect on January 3, 2018. The brief may also be instructive for other third-country firms, including principal trading firms and market participants in the Asia-Pacific region.

The brief addresses three separate compliance concerns:

  • direct impacts from authorisation requirements;
  • direct impacts from ongoing compliance obligations; and
  • direct impacts where firms may be affected by the application of new obligations on the European market participants with which they do business.

Specific issues addressed include:

  • direct electronic access;
  • high-frequency algorithmic trading;
  • market making;
  • position limits for commodity derivatives;
  • straight-through processing;
  • mandatory trade execution;
  • general clearing member obligations;
  • algorithmic trading;
  • transaction reporting; and
  • clock synchronization.

View FIA reports on MiFID II/ MiFIR compliance for US FCMs, 7 July 2017