Groucho Marx and MiFID II

Whilst Groucho and MiFID may not normally be associated in the same sentence, the proposed European Parliament amendment activity going on around MiFID II may make Groucho's observation that: ''Politics is the art of looking for trouble, finding it everywhere, diagnosing it incorrectly, and applying the wrong remedies" particularly apposite for some.

Seriously though, with MiFID II stretching away in 2015, and expectations on serious work starting in 2013, is it a question of observing rather than action ?

Whilst it is probably too early for significant MiFID II action, other than following the amendments activity, one particular investment may be a very productive aid to MiFID II preparation, as well as other regulations. With some banks having over 400 separate regulatory initiatives in play, and regulation being possibly the biggest influence on bank Operating Models these days (as opposed to anything to do with client per se), making sure that the TOM can handle regulatory change effectively, as well as the more conventional subjects of cost and client service, maybe time and money well spent.

How best to progress? Key items to consider may include:

1. An cross-firm inventory of all regulatory obligations and the proceses and resources to maintain it.

2. Connect the thinking on Agility, Cost and Client Service aspects of the TOM with the corresponding agility to respond to new regulatory change (with all the data, process and reporting implications) in a systematic and architected way.

3. Ensure there is clear traceability between those same business processes and controls and all relevant regulatory obligations.

Whether Groucho had it right or wrong, as MiFID II proposed amendments continue to number in the thousands, their implications in the coming years can be ameliorated, at least in part, by revision and action on the Operating Model design now.