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