With just over 3 and a half months until the start of MiFID II, there is a great deal for firms to do, especially those who are Investment Firms. Yesterday the Electronic Debt Markets Association (EDMA) wrote this letter stating that as things currently stand, MiFID II is likely to drive trading off venues, or outside of Europe, in contrast to the objectives of the rules. The reasons focus on the personal data that counterparties are required to give for transaction reporting. A solution is suggested which could still be put in place in time for the deadline. The personal data to be given could also cause issues under the GDPR rules (see here).

This article by Cosmo Wisniewskion the Bobs Guide web site also looks at some of the issues around being ready on time and the clarity still required. According to a survey conducted by DST systems referred to here on the IBS Intelligence site, only 33% of firms are ready for MiFID II and GDPR.

In the meantime, ESMA has updated their document with interim transparency calculations (see here).  The FCA has also updated their MiFID II notifications page (see here) with information on carrying out Systematic Internaliser and Direct Electronic access Notifications.