MiFID II: are you telecoms ready?

Although the Financial Conduct Authority’s July policy statement [1] relented on its proposed MiFID II taping requirements for financial advisers – by allowing analogous notes as an alternative – the rules are a significant challenge for entities that are in scope for the first time. Dave Millett sets out the options for relevant firms to record telephone and electronic communications in relation to transactions in financial instruments.

Dave Millett has over 35 years’ experience in the telecommunications industry. He has worked in European director roles for several global companies. He now runs Equinox (www.equinoxcomms.co.uk), an independent brokerage and consultancy firm. He works with many companies, charities and other organisations, helping them achieve savings of up to 80%. Find Dave on Twitter, @equinoxcomms, or LinkedIn: www.linkedin.com/pub/dave-millett/2/17b/a94.

Recent surveys have shown many companies remain unaware or don’t think they will be compliant with the updated Markets in Financial Instruments Directive (MiFID II) and the accompanying Markets in Financial Instruments Regulation (MiFIR) by the 3 January 2018 commencement date. A poll of senior financial services professionals by corporate finance adviser Duff & Phelps showed just 36% of financial services firms that are subject to MiFID II are confident they will be able to comply in time with the sweeping changes. Another survey by PA Consulting had very similar results. Yet, with the implementation datealready having been extended a year from January 2017, it is very unlikely to be pushed back again.