In less than 6 months’ time MiFID II transitions from an implementation project to a way of regulatory life.
The big question for all firms, in particular asset managers, is whether or not they will be ready for the deadline of 3 January 2018.
It is generally agreed in the market that the overarching impact of the new EU legislation will be greatest for sell-side broker dealers and markets, but there are significant changes for asset managers which need to be provisioned for. In our previous blog entry we noted that such changes included inducements and payment for research, transaction reporting, best execution, taping, DEA, algorithmic trading, information to clients and post-trade transparency.
MiFID II presents a significant documentation challenge for asset managers, the key issues include:
- Scoping the documentation project – creating a new suite of documents, updating existing documents and/or using a side letter approach
- Engaging with key stakeholders
- The client experience and customer facing documentation
- Securing relevant consents from clients
- Getting appropriate sign-offs and maintaining an audit trail
If you would like further information on the MiFID II documentation challenges facing asset managers, including our brochure, please contact Imogen Garner.