Two key pieces of regulation that impact how firms demonstrate transparency to clients when interacting with them throughout the lifecycle of a relationship, went live this week: Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation and the Markets in Financial Instruments Directive II (MiFID II).
 

MiFID II went live on 3 January 2018. In scope, firms will have considered the impact of the regulatory changes being introduced, but may not be aware of the VAT implications of MiFID II in respect of the provision of research.

With just 36 working days remaining of 2017 and until the implementation of MiFID II, we are seeing mixed progress towards compliance, with some firms just completing the first hurdle as they progress through the gap analysis stage. While others have demonstrated strong progress towards implementing solutions and now have the finish line in sight, as we enter the final furlong.

With just 3 months left to achieve compliance with MiFID II implementation due on 3 January 2018, we've highlighted below 7 key areas that are pertinent to most firms across financial services.  

On 3 July, the FCA published policy statement PS17/14 detailing their final rules on conduct of business and client assets as part of the implementation of MiFID II in the UK. In this article we focus on the new conduct requirements and provide a brief outline on the main changes being introduced on best execution, investment research and inducements. 

In addition to changes to market structure, conduct of business and transparency, MiFID II will introduce extensive requirements in respect of internal management, organisational arrangements, individual responsibilities and governance. The reform takes provisions derived from the Capital Requirement Directive (CRD IV) that were originally intended for banks and large institutions, and extends these to all MiFID firms.

With only seven months to go until its implementation date, MiFID II is one of the most talked-about topics in the financial industry. However, we are still finding that a number of firms fall victim to some misinterpretations and common misconceptions about the changes brought about by MiFID II.

With an implementation date of 3 January 2018, the deadline for readying your firm for the required changes is rapidly approaching. However, in a recent Moore survey, it was found that only 7% of firms had started their implementation plans and more than half did not even have a plan in place yet to achieve timely compliance.
 
To aid firms in scope of MiFID II, this article highlights the key milestones you need to work towards over the coming nine months.

The FCA announced the opening of the MIFID II authorisations gateway on 30 January. It is thought that around 600 applications will be submitted over the coming months including new applications for authorisation of organised trading facilities, commodities dealers and data reporting service providers. Similarly, variations of permissions and notifications from existing firms that require a change of permission or passporting rights are expected.