MiFID II may have come a little too quickly for some companies. Its scope, the snail like pace of its formulation and the myriad interpretations of its applications and implications meant much of the EU’s financial services industry had to rush through changes to comply with it.
Many firms struggled to meet the January 3 deadline despite hundreds of people spending the Christmas break rushing to put processes in place in time for the 3 January deadline.
That so many companies were ready in time is an achievement in itself, given that a significant portion of MiFID II’s new rules were still being formalised as recently as July.
This race against time appears to have been particularly challenging with regards to implementing MiFID II’s wide-ranging rules on record-keeping of electronic data communications. By necessity, companies have done what they could to ensure their processes meet the new demands of transparency, accuracy and easy retrieval.
Where a firm has had to take a more tactical approach to compliance, many have found themselves with a patchwork of voice, e-mail, and data recording platforms, with a minimum level of interoperability.
On this basis, it’s likely that many companies only just managed to cross the compliance line with setups that could be impractical to change, expensive to maintain and basically strategically compromised.
The list of day two actions and optimisations at many firms remains large. Its important not to park these risking future regulatory monitoring failure and operational risk deficiency.