application design for mifid ii-compliant operations

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MiFID II Dr. Wolfgang Göb Head of Business Development [email protected] Software Daten Service GmbH Rennweg 97-99, 1030 Wien, AT www.sds.at [email protected] Application design for MiFID II- compliant operations

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Page 1: Application design for MiFID II-compliant operations

MiFID II

Dr. Wolfgang Göb

Head of Business Development

[email protected]

Software Daten Service GmbH

Rennweg 97-99, 1030 Wien, AT

www.sds.at

[email protected]

Application design for MiFID II-

compliant operations

Page 2: Application design for MiFID II-compliant operations

© 2015

SDS company profile

2

Founded 1974, located in Vienna/Austria

Member of Deutsche Telekom Group

170 FTE

SDS solutions are built to

modernize, automate and optimize the back office processes of financial institutions.

Software Daten Service (SDS) specialises in the development of

standard software for the financial industry.

For worldwide 600+ clients, our solutions settle hundreds of millions

securities transactions per year, and serve as backbones of their back

office operations.

SDS is operating one of the largest European automated testing

centers for standard software solutions.

Page 3: Application design for MiFID II-compliant operations

© 2015

Our clients

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Page 4: Application design for MiFID II-compliant operations

© 2015

MiFID – the “Markets in Financial Instruments Directive”

MiFID in a nutshell

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EU affair (plus Iceland, Liechtenstein and Norway)

Published 2004, effective as of 2007

Aims towards a harmonized, competitive and accessible financial market:

− Suitability and Appropriateness

− Best Execution

− Price Transparency

Page 5: Application design for MiFID II-compliant operations

© 2015

“Lessons Learned” from 2008

MiFID in a nutshell

New players on the market, new and complex instruments

Rapid technology advancement

Bundle of regulatory measures:

− EMIR (derivatives)

− MAD (market abuse)

− Basel III (capital requirements)

− MiFID II

MiFID II (MiFID II and MiFIR) published 2014, to be applied starting 2017

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Page 6: Application design for MiFID II-compliant operations

© 2015

MiFID II focuses on several major areas:

MiFID in a nutshell

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Market Organisation

Transparency

Investor Protection

Page 7: Application design for MiFID II-compliant operations

© 2015

Updates address weaknesses in MiFID I

Investor protection and transparency: Best Execution Policy

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Detailed provision of execution policy: “clear, easy

to understand language”

Identification of appropriate target markets for the

distribution of products

Publication of the top five execution venues of the last

year

Ongoing monitoring and communication of changes in

the execution policy

Best Execution Policy

Page 8: Application design for MiFID II-compliant operations

© 2015

Strict rules on advice and granular price transparency

Investment advice and price transparency

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Independent vs. non-independent investment advice

− Declaration which type of advice is given

− Provision of details about how independent advice is achieved

− Independent advisers and portfolio managers may not accept inducements

Pre-trade price transparency:

− Breakdown of estimated fees, commissions, kick-back’s, mgmt. fees,….

- Estimates of total costs of ownership

- Inclusion of individual discounts

− May require “MiFID-II-compatible approximation” or flat fee models

Page 9: Application design for MiFID II-compliant operations

© 2015

Detailed breakdown of total costs

Investment advice and price transparency

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One-off charges:

− Broker commissions, entry- and exit charges, platform fees, stamp duty,

transactions tax, FX costs...

Ongoing charges on an annual basis:

− Management fees, advisory fees, custodian fees…

− Incidental costs (performance fees)

Exit costs:

− Redemption fees, termination fees, switching costs…

To be expressed as a total amount

Granularity may be different from today’s price models

Page 10: Application design for MiFID II-compliant operations

© 2015

Technical challenges

Price transparency

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Product database

Estimates and approximations for charges

Reconciliation with actual fees

Settlement and

Custody

Price Transparency

Advisory Desk

MiFID-compliant pricing information

Pre-Trade advice

Post-Trade Reporting

Product Information

Order Verification

Best Execution

Investor Profile Public Data

Private Data

Pricing

Trading

Page 11: Application design for MiFID II-compliant operations

© 2015

“To monitor … the integrity of the market”

Transaction reporting

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Identification of market abuse on a European scale

Will replace existing transaction reporting regimes like §9 and WAG

Reporting of a wide group of financial instruments:

− Admitted to trading or traded on an EU trading venue. Trading venues include

MTFs and OTFs.

− Underlying instrument is traded on a trading venue

− Underlying is an index or a basket composed of instruments traded on a

trading venue.

Page 12: Application design for MiFID II-compliant operations

© 2015

A new reporting regime emerges

Transaction reporting

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Reporting either direct or via “Authorised Reporting Mechanism (“ARM”)

80+ attributes per transaction (up from 20+), including:

− Identity of the customer and decision maker

− Person responsible for execution

− Algorithms used

− Flags for certain types of trades, e.g.:

- Waiver indicator

- Short sale indicator

- Commodity derivative indicator

Page 13: Application design for MiFID II-compliant operations

© 2015

Technical challenges

Transaction reporting

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Massive reporting volumes

Reporting will be T+1

Full automation required

Data quality and availability

Exception Handling Validation Stage

Report Generation and Monitoring

Reporting Data Pool

ARM

MiFID-relevant Transactions Persons / Parties Data

Reconciliation

MIS Interface

Modifications /

Amendmends

XML/CSV/FpML

Page 14: Application design for MiFID II-compliant operations

© 2015

Retail and universal banks are heavily affected

What is the impact?

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Processes

Back

Systems Processes

Front

Systems

Market organisation

Reporting

Investment Advice

Best Execution

Page 15: Application design for MiFID II-compliant operations

© 2015

Hotspots are advisory desks and transaction reporting

Application landscape for MiFID II

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Derivatives

Customer Master Data

Transaction Reporting

Price Transparency

Advisory Desk

Product Information

Insurance Products

Securities

Orders

Transactions

Order Verification

Analytics, Management Information, Compliance Monitoring

Executions

Page 16: Application design for MiFID II-compliant operations

© 2015

Pressure for an implementation start is rising

Timelines

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Q2 2015 Q3 2015 Q4 2015 Q1 2016 Q2 2016 Q3 2016 Q4 2016 Q1 2017

Implementation and verification

MiF

ID I

I

Impact analysis Decision on

strategic issues

Decision on process and IT

changes

Live operations

Page 17: Application design for MiFID II-compliant operations

© 2015

The next big regulatory wave

Wrap up

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MiFID II is a significant enhancement of the current MiFID regulation

− May fundamentally change business models for product sales

− Will have a significant impact on processes, applications and cost

Deadlines are tight, and immediate action is required

“Transparency is very important so that investors and

regulators are able to know the truth."