MiFID II deadlinesunder further pressure

Christian Voigt Thursday, May 14, 2015

The European Commission (EC) and ESMA haveagreed on an improved process to draft the Level 2 texts for MiFID II. On theback of those discussions, ESMA asked for a 3-month extension ontheir own deadline to submit draft technical standards and the EC grantedit.

While the next Level 2 drafts will now notbe published until September 2015, the benefit is that further changes are lesslikely. It is certainly better for everyone that ESMA and the EC avoid a gameof legal ping pong.

However, ESMA’s statement that this willnot delay the implementation time seems to me rather bold. The initialimplementation plan has been viewed by participants as ambitious from theoutset; having to wait an additional three months before we see any furtherdetail is not helpful.

Looking back at the EMIR implementation,this pattern looks somewhat familiar. The combination of no EU no-actionletter, delayed Level 2 negotiations and a go-live date set in stone in Level1, will doubtless result in increased implementation pressure.

http://fragmentation.fidessa.com/2015/05/14/having-your-regulatory-cake-and-eating-it/

Having yourregulatory cake and eating it

Steve Grob Thursday, May 14, 2015

This morning I read with interest acolleague’s blog post on the delay to the publication of the ESMAtechnical standards from July back to September. Whilst I appreciate that thesethings are complicated, it seems hard to understand how this won’t delay theimplementation date without potentially increasing the very risks theregulations are trying to prevent.

Building software and systems properlyisn’t just a question of resource; it’s just as much about process. Here atFidessa Towers, for example, we work on a quarterly release cycle. Nextquarter’s code is being loaded onto the waggons to be shipped, the release 6months away is being tested, the following release is being programmed and therelease a year out is being designed. 

Only by taking a disciplined approach likethis can we manage to produce high quality software that meets its functionalobjectives and get it properly deployed for customers. For major banks tryingto implement this software, the problem is even worse as they face far greaterconflicting priorities against the same moving global regulatory feast.

I fear, therefore, that the venerable DrVoigt is right and that our industry is being served an unpalatable appetizerof unintended consequences before we have even taken our seats at the table. 

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