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The Haunting of an OTF; the Devil will be in the detail.

[fa icon="calendar'] 30-Oct-2020 07:28:00 / by David Woolcock posted in Banking, MiFID, Regulation, Treasury Management, Treasury, MiFID II, FCA, regulatory reporter, MiFIR, Treasury Trading Solutions, Banking Regulation, treasury trading, ESMA, OTF

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Following on from the MAR report in my last blog comes one on a consultation from ESMA concerning the Organised Trading Facility (OTF) Regime. The accompanying paper provides an overview of the functioning of the OTF regime. It discusses the definition of OTF’s, the use of discretion in the execution of orders and the practice concerning the use of matched principal trading.

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A Ghost of Christmas Past Makes an Early Appearance – ESMA and MAR Haunt the Spot FX Market

[fa icon="calendar'] 14-Oct-2020 11:02:34 / by David Woolcock posted in Banking, Regulation, Treasury Management, Treasury, FCA, FX payments, regulatory reporter, Treasury Trading Solutions, Banking Regulation, treasury trading, PRA, UK, cross-border payments, cross-border

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As we approach Halloween market abuse has come back to haunt the FX market. Our Advent Blog last year covered the ESMA Consultation Paper on the provisions of the Market Abuse Regulation (MAR) and highlighted the fact that spot FX is not covered by MAR.

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Climbing the Mountain and Levelling the Playing Field – a dichotomy solved?

[fa icon="calendar'] 25-Sep-2020 08:00:00 / by David Woolcock posted in Banking, Regulation, Treasury Management, Treasury, FCA, FX payments, regulatory reporter, Treasury Trading Solutions, Banking Regulation, treasury trading, COVID19, PRA, UK, cross-border payments, cross-border

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For some time in the UK the regulators and authorities have tried to introduce true competition to the traditional banks. Much debate has occurred as to the rights and wrongs of allowing a new grouping of Challengers, Neos and FinTech enter the banking market with a lighter regulatory touch to the incumbents.

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The new Lego - building blocks of the new cross-border payment roadmap

[fa icon="calendar'] 20-Aug-2020 15:37:38 / by David Woolcock posted in Banking, Regulation, Treasury Management, Treasury, Payments, FCA, FX payments, regulatory reporter, Treasury Trading Solutions, Banking Regulation, treasury trading, COVID19, UK, cross-border payments, cross-border

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I have been catching up on some light reading in the glorious English sunshine.  One report in particular caught my eye; the Bank for International Settlements (BIS) Committee on Payments and Market Infrastructures released a paper in July

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Uncleared Margin Rules – more regulatory requirements are on the horizon!

[fa icon="calendar'] 27-Jul-2020 08:18:54 / by David Woolcock posted in Banking, Regulation, Treasury Management, Treasury, FCA, regulatory reporter, Treasury Trading Solutions, Banking Regulation, treasury trading, COVID19, fx swaps, UK, EMIR

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The regulation for Uncleared Margin Rules (UMR) was set in motion at the 2009 G20 meeting following the global financial crisis.

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Back aboard LIBOR Reform – full steam ahead in the UK.

[fa icon="calendar'] 20-Jul-2020 11:16:02 / by David Woolcock posted in Banking, Regulation, Treasury Management, Treasury, FCA, regulatory reporter, Treasury Trading Solutions, Banking Regulation, treasury trading, COVID19, UK

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A triumvirate of the Working Group on Risk-Free Reference Rates (RFRWG), the FCA and the Bank of England published joint statements in March and April (see my previous blog  LIBOR Wars) reiterating that firms must move away from referencing LIBOR and reduce the stock of legacy LIBOR contracts.

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Business Continuity from Test to Implementation - What will be the takeaways?

[fa icon="calendar'] 26-Mar-2020 19:41:46 / by David Woolcock posted in Banking, Global Code, FCA, Banking Regulation, COVID19, coronavirus, SMCR

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We have seen many crises in the past, but this one is in many ways unique and I cannot recall a similar set of circumstances in my 43 years in markets. Financial crises have been global before but have originated within the financial system. Natural disasters have been localised as has dislocation due to terrorism and wars. This pandemic is unique as it is the first time we have seen such dislocation in so many countries at the same time. All financial centres are going through unprecedented emergency implementation of disaster planning activation.

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Home Alone

[fa icon="calendar'] 20-Mar-2020 16:50:47 / by David Woolcock posted in Banking, FCA, SFTR, LIBOR, Banking Regulation, ESMA, COVID19, coronavirus

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It is unprecedented in Financial Markets (at least in my memory!) to have so many people working from home globally. We have previously seen localised examples such as on Wall Street after the tragic event of 9/11, but nothing on this global scale. As firms dust off the business continuity plans, some are hitting problems such as systems not allowing remote trading. This requires a tweaking of rule books and system settings. For those deploying a unified, modular platform, the task is somewhat easier when suddenly so many core staff are working from home as any system changes can be made once, and once only. 

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SMCR is here!

[fa icon="calendar'] 09-Dec-2019 08:30:58 / by Richard Ndefo posted in Banking, Blog, Regulation, Compliance, FCA, Banking Regulation, accountability

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On 12th December the British electorate will head to the polls for the third time in four years.  Each political party is asking the public to put their faith in its manifesto and to fund a splurge in public spending after years of austerity.  This has sparked a broader topic of discussion in relation to (ithe extent to which the opportunity to cast our vote represents a chance to hold the conduct of our politicians to account, (ii)  assess the policies of the incumbent party during the previous parliamentary period, and (iii) whether there are more efficient (and frequent) ways of making politicians accountable. 

Meanwhile, today the Senior Managers Certification Regime (SMCR) comes into effect for solo-regulated firms in the financial sector. 

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