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Mifid, Uncategorized

Updated MiFID II Q+As released

With less than 3 months until the start of MiFID II, ESMA has issued updated versions of several questions and answers documents:

  • Market structures (see here) – this includes some new answers on OTFs (Organised Trading Facilities). In particular there are answers (starting on page 42) which state that an OTF must offer at least one financial product, and cannot only offer “REMIT carve out” products”, which are not financial instruments based on MiFID II’s definition in Annex I Section C6.
  • Transparency (see here) – this includes answers on waivers and systematic internalisers.
  • Investor protection (see here) – including new answers on best execution and record keeping.

With the countdown to “go live” in full force, many companies  are struggling to be ready on time. There have been indications from some that those who try to comply on time, but never the less do not meet the deadline, may be treated with sympathy by some regulators for some aspects of the rules (for example see this article on The Trade web site, which relates to reporting requirements)  However, it is recommended that all make full efforts to ensure full compliance.

About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.


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