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.
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
Bringing Harmony to Treasury, Sales and Regulatory Compliance.
[fa icon="calendar'] 08-Jun-2020 07:30:00 / by David Woolcock posted in Banking, MiFID, Regulation, Treasury Management, Treasury, FX, sales, regulatory reporter, Sales Desk, Treasury Trading Solutions, Banking Regulation, treasury trading
Regulations are having a profound effect on the trading landscape alongside a proliferation of Codes of Conduct. In the UK, there are three codes replacing the former NIPS code covering FX, Money Markets and Precious Metals.
Regulatory Reporting and FX Swaps. Or is it FX Strats? Or even FX Packages?!
[fa icon="calendar'] 02-Jun-2020 08:18:11 / by David Woolcock posted in Banking, MiFID, Regulation, FX, FX payments, regulatory reporter, MiFIR, Banking Regulation, ESMA, fx swaps
We have been seeing a lot of discussion and interest concerning a blog I penned in March last year under the title of “Beware the Ides of March - A Drama of FX Swaps Reporting”.
This March, we had a Consultation from ESMA, nattily entitled, “MiFID II/MiFIR review report on the transparency regime for non-equity instruments and the trading obligation for derivatives”, which may equally be causing this issue to be re-visited.
The Best Executed defence means no penalties.
[fa icon="calendar'] 29-Jun-2018 14:43:19 / by David Woolcock posted in Banking, Blog, MiFID, Regulation, Compliance, MiFID II, Best Execution, regulatory reporter, World Cup
As the data publishing season for best execution begins, it is timely to look at what is required, and what will be required going forward.
MiFID II ISINs - If you want to see the sunshine, you have to weather the storm.
[fa icon="calendar'] 23-Feb-2018 12:27:40 / by David Woolcock posted in Banking, Blog, MiFID, Regulation, Compliance, MiFID II, regulatory reporter
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.
T'was the night before Christmas
[fa icon="calendar'] 19-Dec-2017 11:01:57 / by Kathryn Emerson posted in Banking, Blog, MiFID, Regulation, Compliance, MiFID II
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.
Advent surprises and few bells jingled!
[fa icon="calendar'] 11-Dec-2017 11:54:00 / by David Woolcock posted in Banking, Blog, MiFID, Regulation, Compliance, MiFID II, PSD2, Advent
Trick or treat? What ghouls & demons can we expect to be knocking on our doors? MiFID III (yes three!) possibly a big demon?
[fa icon="calendar'] 31-Oct-2017 10:12:46 / by David Woolcock posted in Banking, Blog, MiFID, Regulation, Compliance, MiFID II, ACI, Halloween
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?
Is FX MiFIR reporting getting any clearer?
[fa icon="calendar'] 27-Apr-2017 06:26:00 / by David Woolcock posted in Banking, MiFID, Regulation, Treasury Management, Compliance, MiFID II
MiFID II and MiFIR in the foreign exchange world have generated much confusion. It feels like the regulations are shoehorning the FX market into regulations that are not ideal for the purpose.
MiFID II exposes the need for a regulatory reporting solution
[fa icon="calendar'] 03-Mar-2017 16:54:43 / by David Woolcock posted in Banking, Blog, MiFID, Regulation, Compliance, MiFID II
“MiFID II and MiFIR will change the way banks around the world do business —particularly with respect to the scope of data, communications formats and records that must be maintained.” -Bloomberg
Responding efficiently to the dramatic changes that MiFID II will bring in January 2018 is key to ensuring your organisation continues to succeed and remains profitable. As a bank or branch/subsidiary regulated by a European regulatory authority and operating in the EU, your bank is subject to MiFID II in general terms. MiFID II covers nearly all instruments (e.g. including Forward FX) except for most Spot FX. The confusion regarding the definition and whether spot FX is in or out has been clarified to some extent and relies mainly on the T+2 (smaller currencies up to T+5) and “physically settled” definitions.
Some good news and a cunning plan for the weekend...
[fa icon="calendar'] 11-Nov-2016 10:13:58 / by David Woolcock posted in News, Banking, Blog, MiFID, Regulation, Compliance, PRIIPs, MiFID II
It is heartening to see at last some good news on the regulatory front in Europe. It is now widely expected that the European Parliament and Commission will move to postpone the entry in force of the PRIIPs Regulation by 12 months. This will bring the timing in line with MiFID II. If all goes well the “cunning plan” will move the date of application to 31 December 2017.
Building Societies regulation–SMR, MiFID II, PRIIPs KIDs-what's in store?
[fa icon="calendar'] 04-Oct-2016 12:56:38 / by David Woolcock posted in Banking, Blog, MiFID, Regulation, Legislation, Building Societies
Following on from our previous blog which looked at the journey of Building Society regulation so far, we are going to look at the current situation and future impacts on the sector.