It has now been several weeks since the start of MiFID II, and things are settling down for many since our last post on the topic (see here). In the wider world of Investment Firms, who must comply with a wide set of rules, there have been some issues.
Those subject to the reporting requirements rely on the central reference database known as the Financial Instruments Reference Data System (FIRDS) to be correct. The database needs to be updated daily in order for dependent reporting systems to function. This report on the IFLR Practice Insights web site looks at reporting issues caused by the lag, and also how the industry is generally coping with reporting. This includes transaction reporting under MiFID II as well as issues around the reporting of swaps, ISIN codes and CFI codes.
Smaller advice firms are also struggling with the rules, as reported here on the Professional Adviser site. ESMA also released a few new Questions and Answers updates for example an updated document on the investor protection rules, which can be found here.
On the commodity derivatives side, there have not been any specific announcements for several weeks. This article by Siobhan Hall on the S & P Global Platts web site talks about how for the most part energy and commodities market participants experienced a relatively smooth start to the rules. However, issues do remain with position reporting, and position limits are still not finalised (see the central list here). A report that Trafigura are moving operations out of Europe due to MiFID II rules, as published here on the Reuters web site, will also provide some pause for thought.
We will likely see more updates over the coming weeks.