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The Vintage of 2018

The relief of passing MiFID Day is palpable. After so long, it is hard to remember life before MiFID II was ‘just round the corner’. Now we have turned the corner and it is behind us. So, what is next? More MiFID II. Few firms will be able to say with conviction that all is done. For most, it will be mostly done, leaving room for improvement. With its carefully coded expressions of disdain for the EU’s drip-feed method of publishing requirements, the FCA has made plain its recognition that firms have not had adequate notice of many MiFID details to be able to comply on time. But firms would be wise to take note of the limitations of the regulator’s forbearance – terms and conditions apply. ..

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Remedies of a Healthy Patient

One thing that FCA is good at is trailing its views. So it is that the Asset Management Market Study Final Report contains no real surprises. But lack of surprise does not mean lack of impact. These measures will certainly have that, especially on the pockets of fund managers. And not so much as a pause for breath before going into rule-making mode. CP 17/18 (CP17/18: Consultation on implementing asset management market study remedies and changes to our Handbook | FCA) is the start of the implementation process. ..

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