In my last blog The week that was the MiFID II deadline I highlighted the issue with LEI’s. This time it seems it is the turn of ISINs that are causing some turbulence below the surface of what otherwise has been a great industry effort to get the good ship (MiFID II) launched and implemented without any sharp squalls driving us onto the rocks.
So the 3rd of January came to pass and the City was not plunged into meltdown by the implementation of MiFID II/MiFIR. Some confusion reigned due to the late announcement of 6-month smoothing exercise to the implementation of LEI’s. The summary statement was –
T’was the night before Christmas, when all through the bank,
Treasury Managers were wondering who they should thank,
For the upcoming challenges they were due to face,
And new regulation they have to embrace.
In conversation with clients, one topic that comes up time and again is PSD2. When I ask "So, what are you doing on PSD2" there are broadly two responses, "We have it under control" or "We have a team looking at it" swiftly followed by “it can't be much different to PSD". Can it? The answer is quite simply Yes! How much different PSD2 is to PSD is another story altogether and something that deserves a little more time.
Halloween got me thinking as to what demons the European markets might expect on a spooky night like tonight. What could come knocking at our doors and will they be a trick or a treat?
You would be mistaken if you thought enforcement notices were just the preserve of big banks and individuals. Many smaller regulated banks fall foul of the FCA’s and other authorities’ scrutiny. For FCA regulated firms this is mainly around two important principles of business (Principle 3 & Principle 11). Principle 11 deals with relations with the regulator but the most important one is number three (and in terms of fines a costly one!).