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Less than a month until MiFID II

There is now less than a month to go until MiFID II starts, on 3rd January 2018. Investment Firms who will have to comply with many parts of the rules, such as the different data reporting strands, best execution, client protection, market structures and others, have a great deal of work to do in order to be ready. The research un-bundling rules are causing some headaches, as reported here on the Reuters web site. And transposition, as previously reported here, is still not completed in all member states, as outlined here on the Finance Magnates web site.

In the commodity and energy markets, while there are less requirements for those who make use of the Ancillary Activity exemption under Article 2(1)j of MiFID II, there is still work to be carried out. Firstly, each firm using the exemption must notify their National Competent Authority of such use. Most recently, the FSMA of Belgium has issued their form (see here). In addition, it is necessary to comply with the position limits rules (see here) and also to comply with the indirect position reporting requirements. These requirements are still evolving to some degree. In addition, even at this late stage, not all limits are set. There is therefore a great deal to be mindful of in the next few weeks.

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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