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The European Commission is required to review MiFID 2 by March 2020. The German Finance Ministry kicked things off at the beginning of this year by inviting comments from the industry. Attending the recent FIA Compliance and Regulation Forum, I noted that many of the regulators and market participants seem to prefer targeted adjustments over a large-scale rewrite. So, it appears that MiFID could follow the path chosen for the EMIR review. This is a sensible approach, particularly because the substantial costs of delivering MiFID 2 are still fresh in our minds.
At this point we can only speculate on what will end up in MiFID 2.1. Judging by the comments submitted to the German Finance Ministry, potential areas for update include transparency, market data, the open access regime or third country rules. If you are keen to get your preferred changes into MiFID 2, then you need to start writing your wish list now.
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