MiFID 2 is the most significant asset manager regulation to come into effect for many, many years. In terms of its sheer scale and complexity, it dwarfs anything that's gone before. With the January 3rd deadline looming large, asset managers must really focus on concluding their project plans to ensure compliance. Global asset managers should be in a relatively advanced stage in terms of planning for transaction reporting and product governance. One area of MiFID 2 which is less certain and managers should really focus on, is that of research and bundling. MiFID 2 research and bundling have shone a light on the evident disconnect between the rules that apply in the US under the FCC rules and under MiFID 2. The big fear for asset managers operating on a global basis, is that they may have to run two trading books; one for the US rules and one for MiFID 2.
The positions expressed in this material are those of the author as of June 23, 2017, and may or may not be consistent with the views of Brown Brothers Harriman & Co. and its subsidiaries and affiliates (“BBH”), and are intended for informational purposes only. Furthermore, these positions are not intended to predict or guarantee the future performance of any currencies or markets. This material should not be construed as research or as investment, legal or tax advice, nor should it be considered information sufficient upon which to base an investment decision.