With less than 11 months to go until MiFID II comes into
force on 3 January 2018, the implementation projects of in-scope
firms should be well underway. Following its
June 2016 public consultation, the Department of Finance is
responsible for drafting the transposing legislation, which is due
to be published before the transposition deadline of 3 July
2017.
WHAT SHOULD FIRMS BE DOING NOW?
If they have not done so already, firms should be assessing the
impact of MiFID II on their business model, processes (including IT
processes), policies and client documentation. Firms that have done
this work already should be moving into the implementation phase of
their project.
The Central Bank has recently put industry on notice of its
expectations. In a
speech by the Central Bank's Director of Asset Management
Supervision, Michael Hodson, on 7 February 2017, the following
points were emphasised:
