MIFID II: No more time to wait!

As the entry into force of MiFID II approaches, impacted investment firms are now facing some challenges with the actual implementation. Indeed, although the one-year-postponement of the application of MiFID II was a welcome relief to many investment firms, many complexities remain a few weeks ahead of 3 January 2018:

• The additional client reports require extensive analysis in order to properly define business requirements, hence sometimes delaying the IT developments further down the line.
  
• The trend on the selection of the advisory model rapidly became clear: non-independent status for large institutions and independent status for the smaller ones not benefitting from in-house or group products.
  
• Another implementation pain point is the extended transaction reporting obligations: more instruments in the scope, more data to report, and more players under the obligation to report.
  
• Almost no investment firm will have an automated solution in place to assess and respect the target market distributor obligations.
  
• Investment firms that wish to continue using external investment research will have to decide whether they will pay for it out of their own P&L or whether they will charge end clients.