Esma is set to publish the Mifid II RTS on Thursday 24 September
By Ian Salmon, market consultant, finance
The 24th September 2015 will be a seminal
date for the financial markets.
This is the date that ESMA are set to
publish the various technical standards 'RTS’ for
MiFID II. Many of the high-profile items have been
identified - unbundling, best execution, trade reporting &
transaction data capture – and market commentary has
already flagged many areas of concern and challenge. But one
key part is being overlooked, one that requires significant
effort and investment for the 1st January 2017
deadline and has the potential to derail all other efforts to
Under MiFID II, Article 50 and its
corresponding RTS 25 defines the accuracy and granularity of
the timestamp required to be captured on various records and
reports. The impact of this will be widespread judging from the
cross-references to it from other articles which define
transaction and trade reporting, audit trail and even voice and
RFQ record requirements. Many asset classed not covered by
MiFID I will be caught in this horological net which will
ensnare operators of Venues, their Members, Participants and
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