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London

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2004

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Security Payments Regulation & Compliance Retail banking Wholesale banking Identity Financial Crime

John's blog archive

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John Cant

Managing Director at MPI Europe Ltd

Message Posts: 45 Comments: 22

Bio I lead MPI Europe a niche financial sector consulting firm focussing on regulatory driven, risk, technology and operational change Career History A long term financial sector inmate, I have had a varied career ranging from building equity technology solutions for JP Morgan, to developing derivative and risk management software products, before then embarking on my main consulting career as a KPMG partner and then forming my own consultancy

Blogs

Data Management and Governance

You've been quiet - are you Dormant, Deceased or just Gone Away?

08 Dec 2020

When a financial sector customer becomes less active it is often an important signal that they have reached a new stage in their lifecycle, and critically need specific handling. We will look at some possible customer states that all share this common symptom but require quite different handling and priority from different business functions. The

MiFID

Will MiFID research arrangements change again?

01 Sep 2020

I have been doing some informal polling on impact of the EU's latest proposed changes to the existing MiFID II Research regime across various forums in the last few days. As you probably know, these changes would create a narrowly defined exception authorising the joint payment for execution services and research on small-cap (defined as up to a m...

Data Management and Governance

But it worked in Harrogate!

24 Jul 2020

I have nothing against Harrogate, well not consciously at least. However, over recent months there has been much discussion about unconscious bias in many walks of life - including mention in this article about data used for algorithms. So let's consider the role that preparation of data for regulatory uses might have, and where issues exist, what...

MiFID

Easy to say, but hard to deliver

13 Nov 2019

I attended the Substantive Research Unbundling Uncovered MiFID research conference this week. The panels at this event were made up of a mix of market participants and vendors. The mix made for some entertaining exchanges between brokers and investment managers on the true value of research. One broker opined that some asset managers may feel that...

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John is Commenting on

How to deliver successful KYC automation

I particularly agree with #4 - Don’t underestimate the data challenge. It often merits, in my experience in several large banks, a remediation programme of its own

17 Dec 2020 Reply Read article

Will MiFID II bring Evolution or Revolution to investment research?

Helpfully the FCA’s recent announcement on MiFID II ( https://www.fca.org.uk/sites/default/files/cp16-29.pdf ), reconfirms the analysis above. It clearly agrees that even the Evolution option will require process and system changes as stated above. In their latest paper they point out “Operationally, this will require changes to current Commission Sharing Agreement (CSA) accounts” and then indicate a number of conditions that need to be satisfied. They also confirm that the “hard dollar” Revolution option is consistent with MiFID II e.g. “direct payments by the investment firm out of its own resources”. However, it still leaves the choice of where on the spectrum a firm wants to settle and how exactly it wants to satisfy the rules as being a choice for the firm. It also seems to be taking a different view from the AMF, the French regulator, which will further complicate decision making. We are seeing firms starting to be attracted to options which look at budgeting at a strategy rather than client/fund level. As the FCA notes this “may allow firms to set a budget at a desk-level or strategy level” but only if “the individual and collective portfolios subject to the budget share sufficiently similar research needs.” This may make budgeting easier but will still require a far more robust evaluation of research needs and how they are satisfied than exists in a good number of firms. Whatever the potential approach, it is time to start implementation.

07 Oct 2016 Reply Read article

Will MiFID II bring Evolution or Revolution to investment research?

Given the sea change brexit vote since this was posted a number of people have asked whether the MiFID impact is likely to change - maybe some suggest there be delay or even an opt out for UK firms under MiFID. Well, the short answer is no - not likely. The longer explanation is that the MiFID II live date is within the two year period when we are still bound by EU regulation, also to do business in the EU as currently UK firms would have to comply with at least equivalent MiFID regulations and given the recent FCA announcement of regulation is business as usual, it is hard to see major changes to the research changes for MiFID II for UK firms. I acknowledge that many firms would strongly prefer to avoid the pain that will come with a number of aspects of MiFID II whilst facing the Brexit challenges. There are also some other areas of the MiFID requirements have not been finalised. However, these are unlikely to cause delays - rather the regulations come into effect as planned but only the late defined parts have an extended bedding in period. The best approach is surely to continue implementation programmes for research changes on the same schedule, but where possible build in the extra flexibility for change and more complex post EU exit models.

07 Jul 2016 Reply Read article

MiFID II: Brexit, Pain Points and Other Hurdles

Given as mentioned above that the MiFID II live date is within the two year period when we are still bound by EU regulation and the recent FCA announcement of regulation is business as usual, it is hard to see major changes to MiFID II. There is sufficient uncertainty in many other areas at the moment so speculation that creates more does not help - although I acknowledge that many firms would strongly prefer to avoid the pain that will come with a number of aspects of MiFID II whilst facing the Brexit challenges. The best appraoch is surely to continue implementation programmes on the same schedule, but where possible build in the extra flexibility for change and more complex post EU exit models.

04 Jul 2016 Reply Read article