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Anne Plested

Anne Plested Regulation at ION Markets

The clock’s ticking on MiFID’s extra time

As we edge ever-closer to January 2018, the finer details of MiFID II are yet to fully surface, particularly with regard to RTS 22 and the rules around transaction reporting – undeniably one of the larger pieces of the new regulation. There is still much work to do when it comes to finalising the detailed requirements and the Level 2 RTS are stil...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

The ever-growing MiFID II shopping list

Amongst other things, MiFID II’s transparency reforms intend to clean up the quality of post-trade data and eradicate duplicate prints – long-suffered bugbears for investment firms. But in simply stating the rules, ESMA has left buy- and sell-sides puzzling over just how significant a change this is. A look at the cost benefit analysis the regula...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

No summer break for MiFID II

You may have noticed that the MiFID II Regulatory Technical Standards (RTS) continue to roll off the press at a steady pace signalling finalisation of the Level 2 detail. Last week alone seven RTS documents were adopted by the European Commission, including the long-debated RTS 2 on non-equity transparency and also an RTS on registration of third...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

So much to do, so little time

This week’s closing date for the ESMA consultation, which sets out amongst other things a non-exhaustive list of transaction reporting examples as Level 3 guidance, is a keen reminder of just how much there is to be done for MiFID II. This hefty document, published in December last year, is a crucial step that will allow the implementation to pic...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

And the MiFID II award for early guidance goes to...

Amidst the on-going rumblings about delays to MiFID II, and the budget and planning uncertainty this has created, it’s good to see that market participants continue to press on with implementation. MiFID II includes many new obligations for venues and, for investment firms, knowing what the exchanges will do fills a significant piece of the puzzle...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

MiFID II choice cuts

The overhaul of transaction reporting under MiFID II continues unabated in the latest ESMA drafts, with new obligations and data changes still being introduced. Aimed at improving the quality of data for market abuse investigation, ESMA has introduced a new requirement for transaction reports to be made available to regulators in a common XML temp...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

Doesn’t ESMA time fly!

Looking at the latest changes regarding accuracy of business clocks, now reincarnated as RTS 25, I noticed a number of interesting points in the text. Most importantly, the absence of the usual clause “…applies from 3rd January 2017″, with just the generic phrase stating that the rules will “enter into force on the twentieth day following that of...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

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 n...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

MiFID II data disaggregation - be careful what you wish for!

Under MiFID II pre- and post-trade data is required to be made available in an unbundled fashion – ultimately the regulator is aiming to drive down data costs. So where trading venues sell their pre- and post-trade data in the same ‘package’ they will be required to also make it available separately at a reasonable cost. Setting aside the cost dis...

/regulation

Anne Plested

Anne Plested Regulation at ION Markets

ESMA stops short of a no-action letter

Having taken several years to get through the review of MiFID, it was interesting to hear from ESMA chair Steven Maijoor last week that there is an appetite to “explore the mechanisms to address regulatory adjustments in a flexible and agile manner”. Neither national authorities nor ESMA have any tool like the ‘no-action letter’ employed in the US....

/regulation

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