MiFID II seemed so far away when it was pushed back until January 3rd 2018!!
This has been a long time coming, and despite the looming deadline, firms are still trying to work out what they need to do. This is causing challenges for them as they try and decide where to focus their resource and what is the highest priority…?
MiFID II has widened on the original MiFID directive to include extended communications capture. This includes pre and post trade communications information as well as any interaction that leads up to a trade but is not executed.
“Such telephone conversations and electronic communications shall also include those that are intended to result in transactions concluded when dealing on own account or in the provision of client order services that relate to the reception, transmission
and execution of client orders, even if those conversations or communications do not result in the conclusion of such transactions or in the provision of client order services.” –
Article 16 (7) MiFID II Directive 2014/65/EU
This is a huge challenge for small to medium sized business that do not have the resource or expertise in house to be able to procure and manage the upgrade and deployment of a new voice recorder, telephony system and or holistic technology.
The business need to ask themselves the questions, as it helps them on starting the journey towards MiFID II compliant communications:
- What should the technology environment look like for optimal efficiency?
- What are you wanting to do with the information once you have captured it?
- What are the use cases your firm are looking at?
The answers to these questions drives the need for different deployments and configurations of technology which may or may not already be in place.