Heavy with flu I forced myself out of my codeine haze to digest the latest news on, you guessed it, MiFID.You may be thinking I have swallowed one to many cold and flu capsules, as I am about to launch into another rave about the Market in Financial Instruments Directive.
Sometimes it does feel like groundhog day here at FinancialTech Insider but perhaps with good reason. PJ DiGiammarino and his team at JWG-IT, the think tank working with buy- and sell-side firms to make sense of MiFID, has gleaned from the 25 workshops it has held over the last few months with 30 financial institutions, 100 (only 100, you say?) MiFID decisions that firms need to make fairly soon before the day of transposition to MiFID in November.
Based on 150 days of collaborative research amongst the 30 firms that attended its workshops over a 12 month period, JWG-IT has identified the "known unknowns" of MiFID, which it colourfully equates with the 15th century's War of the Roses because of the loosely connected "fiefdoms" within Europe all vying for control over the evolving "common market."
JWG-IT's full report entitled, "MiFID: The roadmap to implementation," is somewhat of a 'Hitchiker's Guide to the Galaxy,' as it not only highlights where the current gaps exist in knowledge and preparation; best execution, trade and transaction reporting, MiFID's treatment of outsourcing, record keeping and customer data management; but it also provides reference implementation plans and frameworks.
And the aim of all this; well to put it bluntly, with less than 200 working days left until MiFID becomes law, it is a not so gentle reminder that firms need to pull their finger out of their proverbial ... They say it is time for action even on the 'known unknowns' (when someone has defined the known knowns of MiFID - the only known perhaps being that MiFID is going to happen - please let us know.)
David Seacombe a director of JWG-IT had this cautionary note for firms:
"Testing of new processes should start within the next two months but it will be very difficult to meet the required timetable, because many small firms still have no access to agreed architectures."
To download a free copy of the report go to www.jwg-it.eu and look under the MiFID docs section.
1 comment:
Some very good audio content I've heard on the issue at www.mifidpodcast.com
Free to access too which is pretty cool, since usually one would have to pay to attend a speaking event.
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