All together now

A common approach will be key to minimising the fallout of MiFID II implementation, particularly around the extra data required for record keeping and transaction reporting and for algo identification.

I’m hopeful that the ‘final’ Technical Standards due later this month will have at least dropped requirements to include static data. Do we really need multiple systems storing and passing around redundant static instrument, client and trader data? ESMA only defines content and format at the point of report submission, recognising in December’s draft RTS 34 that “prescribing a specific format in which the records should be maintained might result in operational difficulties for trading venues.”

With MiFID II touching every corner of financial services, limiting change to only those systems that actually require the imposed extra attributes seems eminently sensible to me and should help to contain its impact. The sooner there is clarity on the technical standards the better, and though I have my reservations about the finality of the version expected at the end of September, it will become the new song sheet for us all.