monitoring

On 8th May 2018, CPMI-IOSCO released anonymised updates on the three critical risk areas where central clearing houses are scrambling to meet the business and regulatory demands as set forth in the 2014 Principles for Financial Market Infrastructures (‘PFMIs’). These three are recovery, coverage of financial resources, and liquidity stress testing.

Many people watch the movement of stock market indices, and perhaps also interest rate changes, and possibly even foreign exchange movements: but who considers with much frequency or depth how a corporate issuer paying its dividend or interest rate coupon figures out how much to send to each beneficiary, or how it gets paid out and finds its way to their individual accounts in some far-off country? For those who do not particularly think about what is behind a light switch such that a room is well lit at night, or ask themselves about how clean water arrives at their tap, both hot and cold, they are also not likely to consider how stocks and bonds are looked after when their savings are invested in them. Most of the time, all of this infrastructure works without further consideration.

MiFID II is much discussed, and rightly so. It is a major capital markets Directive affecting a large chunk of the world’s financial system, with effects that will be felt across the world. How this will play out in a practical sense is one of the unknowns of these coming months and longer. Market professionals appreciate that its precursor, MiFID, came to have a major influence on the way capital markets trading takes place, notably in the fragmentation of Europe’s national equity markets.

And with just over three months before MiFID II comes into force at the start of January, there is indeed much hard preparatory work underway, head-scratching, confusion, repositioning of businesses, and human resources redeployment. Given the changes in trade reporting, the IT component is heavy – and it was difficulties with IT preparations that led to a one-year reprieve.

Today marks an exciting development at Thomas Murray IDS Australia and New Zealand, as we announce the Australian release of our multi-purpose software tool SupplierSelect for Financial Services (SupplierSelect). SupplierSelect is suitable for Australian Superannuation Funds with in-house investment teams and will help them appoint, monitor, and manage financial services providers. It is designed for business leaders as it provides audited transparent decision making.

My colleagues and I have been uniquely privileged to see a wide range of Fund operational challenges on a regular basis. One that is very familiar to us is an Institutional investor making major procurement decisions or monitoring key service providers with the use of an in-house spreadsheet. The administrative challenges of drafting, issuing, re-issuing, and scoring complex due diligence questionnaires and policy reviews can be formidable.

Possibly the most complex piece of capital markets legislation to hit the markets since the Dodd-Frank Act in the US in 2010 is nearly upon us, the European Union’s revamping and extending of the Markets in Financial Instruments Directive (MiFID I) promulgated in 2004, with effect in November 2007. That was one very long decade ago, given events in financial markets over the period.

Financial market professionals working in the EU and outside it will be affected, some heavily. Its immediate, most visible impacts are on transaction order transparency pre-trade, transaction reporting post-trade, and the separation of research from bank/broker trading commissions. The changes will likely go further: as with most rearrangements in the intricate chains of financial services, there will be knock-on effects beyond the immediate targets of the authorities, though what they will be is hard to define beforehand.

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