MiFID II

Limiting costs and charges disclosure under MiFID II and PRIIPs: issues and misinterpretation

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On 13 September 2017, JWG held their third Client Management Special Interest Group (CMS), with attendees from over a dozen buy-side, sell-side and technology firms meeting to discuss existing issues on cost and charges disclosure under MiFID II and PRIIPs obligations.  The meeting was a productive one, whereby participants expressed concerns on the following areas:

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Defining systematic internaliser under MiFID II

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With only 3 months left before the implementation of MiFID II, on 28 August 2017 the European Commission published a delegated regulation which added to the definition of a systematic internaliser.  Under MiFID I, the SI regime was limited to equities transactions but, under MiFID II, it has an increased scope.  A systematic internaliser is an

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Introducing Our Daily Briefing, Direct to your inbox

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Introducing the new Clarus Daily Briefing. Curated market information direct to your inbox. Swap rates, volumes and Central Bank rate expectations every day. Make sense of daily trading activity in less than 2 minutes. We offer a free two-week trial before your paid subscription starts. Daily Market Commentary We always aim to improve the general […]

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Disentangling transaction cost disclosure: a MiFID II and PRIIPs obligation

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A granular understanding of the several types of costs and charges is important for all market participants.  These can have a substantial effect on investors’ returns (see graph below) and, if disclosed effectively, should facilitate market efficiency.  With this in mind, regulators have gone to considerable lengths to implement all the necessary requirements related to the disclosure of all costs and charges

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MiFID II: Why Research is in the News

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There have been many recent articles on Banks have to charge for Research as required under MiFiD II, see here, here and here, so I thought I would look into the detail. Inducements The relevant text in the EU Commission Delegated Directive is in Chapter IV: Inducements, the title providing a clue to the intent. This Chapter […]

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Algo trading: a glance at MiFID II

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New rules on algorithmic trading, such as those quickly approaching from MiFID II, are cause for preparation across the industry, with various regulations in this sphere also impacting the buy-side. So, in this article, we’re going to take a look at some of the ways that regulation is currently, or will soon be, impacting algorithmic

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Article: “What a year: MiFID II/MiFIR, EMIR RTS, SFTR and SEC SBS”

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The most recent edition of the Journal of Securities Operations & Custody (Volume 9 Number 4) features an article by Lloyd Altman entitled “What a year: MiFID II/MiFIR, EMIR RTS, SFTR and SEC SBS”.

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MIFID II Transparency will leave us in the dark

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We run the SSTI and LIS thresholds over US SDR data. We anticipate that over 80% of EUR swaps will not be subject to pre-trade transparency. Post-trade transparency will not be much better. 75% of the risk traded will remain dark for up to four weeks. We are intrigued to see what the APAs will […]

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Our Response to the ESMA Trading Obligation Consultation

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ESMA published their latest Consultation on Trading Obligation for Derivatives under MIFIR on 19th June 2017. As we stated back in June, we have concerns about the quality of the data used to determine the Trading Obligation. We have therefore offered to make all of our SDR data available to ESMA as part of our response to the […]

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MiFID II Product Governance Framework- Changing the face of Investor Relations

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Introduction With less than 5 months left before the deadline for MiFID II on 3 January 2018, firms are still grappling with the implementation of MiFID II.  One key area is the new product governance framework which has been enacted with the objective of ensuring that firms act in the best interests of their clients

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