The actual effect, so far, seems to have been the opposite, at least if we look to our Nordic friends. Both Denmark and Norway have faced transparency issues after having gone from reporting to one main exchange facilitator to opening up for reporting to any exchange facilitator.
Here in the UK, it was always a given that there would be challenges since the MiFID II regime is designed for the EU market. There have so far been issues reported regarding product governance, understanding the scope of products affected and how to approach the necessary assessment. In the last six months, the FCA has received 1501 phone queries regarding MiFID II, 187 of which came in after the implementation date.
With a serious lack of clarity of the regulations together with the lack of time to focus on the processes, procedures, and interpretations, hasty decisions are being made. For some, this quick decision-making may even lead to regret in the future.
One thing is for sure: MiFID II will continue to challenge banks, together with the other regulations which are just around the corner. The critical challenge still lies in understanding the risk, implementing the actions needed and doing this in a profitable and efficient manner.
What have been your greatest challenge after MiFID II came into force?