Which side of the debate are you on? Is MiFID II:
- A threat - upsetting the status quo, placing new, unnecessary, even unacceptable demands on firms and employees, which will ultimately do little or nothing to address the shortcomings and risks faced by our industry; or,
- A great opportunity - the chance to restore investor confidence and trust, root out bad apples, combat market abuse, and repair our damaged reputation after the financial crash
Whatever your thoughts, you do have a choice. Sure, compliance of MiFID II is going to be essential, but it's also about how you comply - and that's where you get to decide.
So, will you walk towards a brighter future come January 2018 and show clients you really care? Or, will you blame it on the regulator and wait until the fines roll in again?
If you're willing to see MiFID II as an opportunity, follow these 4 steps to a brighter future:
- Conduct an Impact Assessment - assess the 'current state' of your policies on execution, disclosures, inducements, commissions, suitability and appropriateness tests, conflicts of interest, codes of conduct, etc.
- Get the tone right - be careful what language you use about MiFID II. Negative comments, a perceived lack of control and time pressures can create inertia. Instead, get senior management buy-in and commitment, encourage collaboration, appoint MiFID II or customer champions, create energy, and give ownership - put different people in charge of key areas (eg investment research, execution, client interests, etc). Remember, a positive attitude can be contagious and drive forward change.
- See the bigger picture and change the culture - review our firm's entire approach to the principle of Treating Customers Fairly. Is it genuine and sincere, hollow or bare minimum?
- Benchmark progress - plan to carry out regular reviews to ensure that any policy or process changes have been implemented fully and are working as you envisaged; reach out to regulators, industry bodies, tech firms and other interested parties to identify best practice and benchmark progress; look for improvements to existing practice.