We have all heard stories where firms who are already familiar with regulation are struggling with MiFID II. In his speech today, Michael Hodson highlighted how firms who to date have not been regulated may need to be.
This is an area we are actively engaged on with a number of clients as the adjustment in moving from an unregulated business to one that is regulated, can be difficult.
Firms who deal on their own account or undertake algorithmic trading will need to undertake a detailed assessment of their current activity to see if it requires an authorisation under MiFID II.
Additionally, as you will be aware, MiFID II also removes or narrows existing exemptions currently available under MiFID. This is particularly the case for some proprietary traders and other businesses that deal in financial instruments on their own account in the course of an otherwise unregulated business model. The Central Bank has recently issued a warning to firms who routinely engage in investment activity, to take the necessary steps to ensure that they operate in compliance with MiFID II from 3 January 2018.