Whilst the scope of MiFID II is wide, the conference honed in on the requirements for reporting across the industry. All of the topics were covered in panel discussions and this enabled a lively debate amongst panelists and the wider audience. There are some key implementation challenges relating to reporting and these were brought into sharp focus at the conference.
Some of the key topics covered included transaction reporting for firms, recordkeeping requirements, liquidity and transparency requirements and implementation timelines.
Tony took part in two critical panel discussions. The first covered reporting requirements for venues and ARMs (approved reporting mechanisms). A good discussion covering the venue requirements, the need to avoid duplication and the role of the ARM, especially in relation to the large multi-entity firms needing to make choices over whether to report via a central hub directly to their NCA (National Competent Authority).
The second focused on the control environment required around transaction reporting. Here the discussion shifted from the requirements themselves to the enhanced control framework necessary to ensure and (importantly) evidence compliance. A lively debate veered towards the requirements within the senior managers regime (SMR) which has recently been enforced to the quality assurance needed under the current MiFID requirements that firms still fail to get right.
It is clear that whilst ESMA has been transparent on reporting requirements, there is still much for firms to do to be compliant by the (proposed) 3 Jan 2018 deadline. There are also a number of areas that still need to be clarified by the regulator but in spite of this firms need to be proactive in implementing system and process changes as soon as possible to ensure they have confidence in meeting the deadline.
In addition, Tony also showcased the new award-winning GFT Regulatory Change Management Solution which allows firms to accelerate their regulatory programmes and keep abreast of ongoing regulatory change. It has already received extensive positive feedback from fellow industry experts.
