When I showed this blog to a chum of mine at another bank, he said my blogging’s now becoming like a London bus – you get nothing for two years and then two come along at the same time. He’s got a point! 🙂
Apparently it’s called ‘bus bunching’…
Anyway, I want to look at regulatory trade and transaction reporting and given we’ve just gone live with five brand new reporting regimes courtesy of MiFID 2, as well as the complete rewrite of EMIR trade reporting back in November last year, I really should have tried harder with my timing on this one because the ideas behind this blog were originally kicked around back in 2014 when I was at Barclays and I worked on the “what does good look like” for EMIR trade reporting first time round. Still, like a bus, better late than never and you’ll still be in good time to apply any findings ahead of SFTR and the CFTC’s rewrite of their Part 45! Continue reading
A contents page.
How hard can it be!
Not exactly rocket science…
When I see folks pick up MiFID II or MiFIR for the first time (or any regulation come to think of that!) their eyes glaze over.
When they flick through the first dozen or so pages you can feel the pain of not knowing what the heck these 100’s of pages of regulations are all about and how to make sense of it all. And to be honest, the EU seems to go out of its way to further this frustration by not providing a contents page. Maybe they feel we don’t need one. Continue reading
Truth be told, I’ve got a soft spot for MiFID – the Markets in Financial Instruments Directive that was introduced back in November 2007 to shake up Europe’s equity markets and create a common set of rules for a single market.
I cut my teeth on the regulation when I tore the thing apart to understand the impact that the introduction of MTFs would have on buy-side trading desks. I didn’t care too much about the regulation at the time per se because all I was focused on was designing trade execution algorithms, but it sure did give me an introduction into how regulations were coming of age!
Six years down the road and the same regulation is still paying my way :-), this time courtesy of the MiFID Review. The folks that are responsible for writing this stuff typically stick a date in the diary for ‘T+5 years’ to rectify things that didn’t quite play out first time round.
To be clear, the MiFID Review is a complex piece of legislation. It is made up of MiFID II, a huge overhaul of the original regulation, because technologically a lot has changed, and MiFIR, an amendment to EMIR, because the launch of the MiFID Review collided head on with the European response to global OTC swap reform. Continue reading
OK, second time this month I have had this “isn’t MiFIR part of EMIR” conversation, least of all the number of times I have had it this year, so let’s have a go at clearing this up.
It’s probably easier to understand how this all came about if you wind back the clock to April 2010 when CESR issued technical advice to the Commission recommending possible revisions to the Markets in Financial Instruments Directive (MiFID) that was implemented way back in November 2007.
This formed the basis of what was to be known as the ‘MiFID Review’.
The primary objective of the MiFID Review was to bring areas of the market that had escaped the MiFID net, such as broker crossing networks and dark pools, into scope, as well as update the regulation to capture market advancements in technology, such as automated trading and high frequency trading.
Now wind forward the clock, and in stumbles EMIR, which clearly had some overlap with what was trying to be achieved with the MiFID Review. Continue reading