the impact of mifid ii and mar on communications compliance · 2019-02-15 · the impact of mifid...

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WH

ITE

PA

PE

R

June 2017

The Impact of MiFID II and MAR

on Communications Compliance

White Paper

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1 Introduction ............................................................................................................................................... 3

2 Overview of MiFID II and MAR ................................................................................................................. 4

3 Delta to current Communication requirements ........................................................................................ 6

4 Obligations deep dive ............................................................................................................................... 7

4.1 Capture ............................................................................................................................................. 8

4.2 Monitoring ......................................................................................................................................... 8

4.3 Evidencing ........................................................................................................................................ 9

5 Implementation challenges .................................................................................................................... 10

5.1 Tracking and analysing .................................................................................................................. 10

5.2 National transposition ..................................................................................................................... 10

5.3 3rd country complications .............................................................................................................. 10

5.4 Extraterritorial application ............................................................................................................... 10

5.5 Interdependencies .......................................................................................................................... 10

5.6 Digitisation of voice trading ............................................................................................................ 10

5.7 Keeping records of unexecuted orders .......................................................................................... 10

5.8 Use of mobile phones within firms ................................................................................................. 11

5.9 Trade reconstitution........................................................................................................................ 11

5.10 Flexibility on formatting of records ................................................................................................. 11

6 Implementation approach ....................................................................................................................... 12

7 Conclusion .............................................................................................................................................. 14

The impact of MiFID II and MAR on Communications Compliance

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1 Introduction

Financial services organizations worldwide are under increasing pressure from mounting global

regulations. The latest regulations MAR (effective since 3 July 2016) and MiFID II (takes effect on 3

January 2018) are broadening the scope of employees, asset classes, communication channels, and

devices that need to be recorded and monitored, while also mandating proof of compliance and imposing

escalating fines for compliance lapses.

NICE has asked JWG – Making Sense of Financial Regulations – to review in this White Paper the

communications related requirements under the MAR and MiFID II frameworks, as well as other relevant

legislation. JWG also explains in this White Paper the key challenges for complying with MAR and MiFID

II with regards to policies and procedures, applications, data and infrastructure.

In the Summary of this White Paper we will highlight the NICE solutions that are available to help

financial institutions to comply with these growing financial communication regulatory requirements of

MAR and MiFID II.

For more information and the latest updates on MiFID II with regards to communications compliance go

to www.HolisticSurveillance.com/trading-regulations.html

http://www.holisticsurveillance.com/trading-regulations.html


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2 Overview of MiFID II and MAR

The first Markets in Financial Instruments Directive (MiFID) came into force in November 2007

replacing the Investment Services Directive. MiFID had relatively modest aims of improving

competitiveness and to ensure adequate levels of investor protection were maintained within financial

markets across the European Union (EU).

As with most EU legislation, MiFID obligated the European Commission to review the application and

impact of the regime for many years after its implementation. MiFID followed the financial crisis of 2008

and consequently, the review resulted in new legislation; comprised of the second Markets in Financial

Instruments Directive (MiFID II) and the Markets in Financial Instruments Regulation (MiFIR). This new

legislation deals not only with the shortcomings of MiFID but also with the lessons learnt during the

financial crisis, taking the growing complexity of technology and financial innovation into account.

Therefore, although the origins of MiFID II can be traced back to its precursor, the new Directive and the

accompanying Regulation (MiFID II/R) represent a complete overall of the existing obligations. Although

these changes were set to take effect from 3 January 2017, growing concern surrounding whether the

regulator and the industry would be ready in time, resulted in the decision to delay the effective date of

the legislation, until 3 January 2018.

In parallel EU policy makers reworked the market abuse framework, producing a new Market Abuse

Regulation (MAR) and the recast Directive on criminal sanctions (MAD) which were drafted and adopted

in conjuncture with MiFID. Although the provisions listed in Article 39(2) of MAR will apply from 3 July

2016, many MAR requirements will become applicable on the MiFID II deadline (3 January 2017), due to

their affiliation with MiFID II.

The new MAR was established to ensure that regulation keeps pace with market developments, such as

new technology, and aims to strengthen the fight against market abuse across commodities and related

derivative markets. MAR expands the definition of Market Abuse to include more offences including,

attempted insider dealing and the manipulation of benchmarks. It also increases the obligations on firms

by shifting the emphasis towards ‘intended’ abuse and global monitoring.

Whilst MAD complements MAR, by requiring all Member States to provide harmonised criminal offences

of insider dealing and market manipulation, the new Directive is not adopted in the UK. Even so, many

regulations, including the Criminal Justice Act 1993, Fraud Act 2006, Financial Services Act 2012 and

Companies Act 1980, protect the industry from market abuse offences.

With MAR and MiFID II together, they are set to change the regulatory landscape as we currently know it.

The impact on banks and other financial institutions will be significant. MiFID II will ultimately result in a

more transparent market place with customers receiving more information than ever regarding the nature

of products and services offered. This will drive competitiveness in financial markets and, in the end,

enable firms to leverage the MiFID II challenge into an opportunity to create an enhanced customer

experience. Whilst MAR has enormous implications for the scope of market abuse monitoring.

Communications is an area of significant impact in terms of both regimes, with new and more prescriptive

requirements across trading, investor protection, reporting and governance work-streams (see figure 1).

This means that firms will be required to capture a much larger scope of data, across a much larger

scope of activities, store it for longer periods of time, apply more robust monitoring and real-time analytics

to it and then be much more effective and efficient in evidencing this process to the regulator.


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Stream Records

Investor

protection

Client classification: initial assessment of suitability and appropriateness as well as changes to the status of the client, by whom and when

Providing information to clients, including marketing communication and investment research

Recording details of the product and service offered

Best execution stats

Trading

Execution of the order: including logging how aggregated orders / splits are dealt with, identifying the amount allocated to each client with date and time of allocation; re-allocation; revealing inducements and giving appropriate warnings on risks; records kept on sending and receipt of order by client

Noting what the internal and external rules of conducting trades were at the time

Records that support trading execution decisions, e.g. pre and post-trade analytics

Reporting

Disclosing pre and post trade data to the market as close to real time as technically possible

Maintaining records of execution of client orders

Maintaining a record of transactions

Recording periodic statements sent to clients

Governance

Records that show how the firm is safeguarding client assets

Noting activities that might engender detrimental conflicts of interest

A tamper-proof environment with auditability of any changes or deletions and why they were made, when and by whom

Maintaining records of the firm’s internal organisation, policies and procedures for compliance

Maintaining records of written reports to senior management

Maintaining records of complaints received and how these were dealt with in writing

Figure 1: Communications obligations across work streams

Ultimately, this is going to require firms to reconsider several key business decisions. Initially, firms will

have to rethink their commercial strategy focusing particularly on the products offered, trading platforms

operated and the sustainability of certain business functions. Firms will also have to determine the impact

of the legislation from an operational perspective and the legislation is likely to impose a great degree of

change in the trading workflow, such as; how certain products are traded, how traders or business

functions interact with clients and how clients are categorised. The onerous data capture, monitoring and

reporting requirements under MiFID II and MAR will heavily impact technology systems.


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3 Delta to current Communication requirements

For most firms, the logical place to start with these new communications related requirements will be to

review the level of change from existing communications requirements under the existing MiFID

framework, as well as other legislation.

MiFID I requires records to be kept of its business and internal organisation, including all services and

transactions undertaken by it, which must be sufficient to enable the appropriate regulator to monitor the

firm's compliance with the existing requirements with respect to clients. This is typically interpreted to

mean communications with clients regarding classification, suitability and appropriateness, product and

service offering and best execution.

When analysing the new requirements there are 4 key deltas:

Activities to be captured: The combination of MiFID II and MAR greatly expand the number of

activities which need to be captured. In particular, MiFID II, being much more prescriptive than its

predecessor. Activities such as all telephone and electronic communications and market

communications are now explicitly in scope.

Data to be captured: The number of data fields which must be captured is also greatly increased

from current obligations. For example, for transaction reporting purposes the number of required data

fields has expanded from 23 to 65. This fact in combination with the increase in the number of

activities which need to be captured meant that the net effect is a massive expansion in the

necessary capture capabilities.

Monitoring: The emphasis in both MiFID II and MAR shifts away from the existing emphasis on

simply capturing records in order to be able to retrospectively understand any problems or

discrepancies towards obligating firms to be actively monitoring and running analytics against their

data in order to identify issues prior to their occurrence. This includes monitoring phone records of

transactions (MiFID II) and monitoring communications for the intent to commit any form of market

abuse (MAR).

Evidencing to regulators: Obligations regarding providing evidence to regulators are set to become

much more invasive which will necessitate greater data retrieval and reconciliation capabilities. The

focus of the new rule is on being able to demonstrate compliance to the regulator on request on an

ad hoc basis.

Understanding these deltas is crucial to determining the impact and implementation strategy for these

new regulations. However, more fundamental is that the existing requirements are being met effectively

and efficiently to the correct extent. The reality is that for many, a MiFID II communications

implementation begins with a remediation of existing requirements which have not been implemented

fully.

There are also a significant number of firms which only come into the scope of these rules under MiFID II,

as it widens the scope of an ‘investment firm’. For these firms looking at the delta from existing

requirements is redundant as they will have to implement the full set of new requirements from scratch.

This will be the case in particular, for many commodities trading firms and firms which exclusively deal on

their own account.


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4 Obligations deep dive

This is an overview of the communications related requirements in MiFID II and MAR:

Area Detail

Activities to be

captured and

stored

A non-exhaustive list of minimum records have been prescribed to harmonise practices across the EU. Delegated Acts 79,80 MIFID II

Recording of all telephone conversations and electronic communications is now required. - MiFID II article 16.7

ESMA considers that some internal calls are subject to the MiFID II recording requirement where the internal call in question ‘relates to or is intended to result in transactions’ in the provision of investment services subject to the telephone recording requirement. ESMA technical advice 2.6 MiFID II

The content of face-to-face conversations with clients should be documented (by a file note), with the minimum content of the file note prescribed. ESMA has noted that this record need not be kept in a minuted form, specifically, but should be kept in a durable medium. ESMA technical advice 2.6 MiFID II (FCA have clarified that these do not necessarily need to be taped)

Collect and keep all records of insider lists, market soundings and investment recommendations Market Abuse Regulation

Monitoring Firms must take reasonable steps to prevent employees and contractors engaging in telephone conversations and electronic communications on privately owned equipment that the firm is unable to record or copy. Firms can adopt a proportionate, risk-based approach to monitoring phone records of transactions ESMA technical advice 2.6 MiFID II

Monitor all client communications for any investment recommendations meeting the criteria laid out in the Market Abuse Regulation in order to ensure appropriate disclosure is provided

Monitor communications for intent to commit market abuse - Annex II Section 1 MAR

Evidencing to

regulators

An investment firm shall, in relation to every initial order received from a client and in relation to every initial decision to deal taken, immediately record and keep at the disposal of the competent authority at least the details set out in Section 1 of Annex IV to this Regulation to the extent they are applicable to the order or decision to deal in question. EC Delegated Regulation of 25.4.2016 article 74 MiFID II

Investment firms shall establish, implement and maintain accounting policies and procedures that enable them, at the request of the competent authority, to deliver in a timely manner to the competent authority financial reports which reflect a true and fair view of their financial position EC Delegated Regulation of 25.4.2016 article 21(4) MiFID II

Figure 2: Overview of communications related requirements in MiFID II and MAR


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4.1 Capture

Telephone conversations (MiFID II Article 16.7): All telephone and electronic conversations are now in

scope for recording including internal calls where the internal call in question ‘relates to or is intended to

result in transactions’

Order records (MiFID II Delegated Acts 79, 80): All order records must be kept for the much-expanded

scope of MiFID II activity in terms of in scope instruments, products and trading venues. Records are

needed for all conversations involving a firm’s representatives when dealing, or intending to deal, on own

account. Where orders are communicated by clients through other channels than by telephone, such

communications should be made in a durable medium.

Face to face records (MiFID II ESMA technical advice 2.6): The content of face-to-face conversations

with clients should be documented (by a file note), with the minimum content of the file note prescribed.

Investment recommendations (MAR Article 3.1): The contents of any investment recommendation

provided to a client must be kept. The difficultly that firms are facing here is the sheer amount of work and

effort that will go into being able to track who has said what to who and when. A person may make

dozens of recommendations each day over the phone or face to face – that’s how relationships between

the sell-side and buy-side are nurtured. To comply with MAR, the very essence of how business is

conducted will need overhauling.

Trading records (MAR Article 8 and 10): Any employees that have access to or come in contact with

Material Non-Public Information must be recorded.

Benchmarks (MAR Article 3): Firms that are a benchmark submitter must capture all communications

with other submitters, within the same firm, or externally.

4.2 Monitoring

Telephone records (MIFID II Article 16.7): Firms must take reasonable steps to prevent employees and

contractors engaging in telephone conversations and electronic communications on privately owned

equipment that the firm is unable to record or copy. Firms can adopt a proportionate, risk-based approach

to monitoring phone records of transactions

Investment recommendations (MAR Article 3.1): A clear distinction will need to be made between

hard facts and opinion, estimates or interpretations – and any forecasts and price projections will have to

be labelled as such. If any of the inputs are considered to be unreliable, these will have to be disclosed.

Conflicts of interest (MAR Article 3 and MIFID II Article 38): A conflict of interest is defined as arising

if relationships and circumstances exist that may reasonably be expected to impair the objectivity of the

recommendation. This captures commercial relationships (e.g., market making for the issuer’s

instruments) through to positions/holdings that the recommender may have in the relevant issuer.

Intent (MAR Annex II Section 1): Firms will need to monitor all forms of communications for Fraudulent

Trading Practices and Intent.


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4.3 Evidencing

Evidencing (MiFID II EC Delegated Regulation of 25.4.2016 article 74): An investment firm shall

arrange for records to be kept of all services, activities and transactions undertaken by it which shall be

sufficient to enable the regulator to fully understand, upon request that the investment firm is meeting its

obligations

Telephone conversations (MiFID II Article 16.7): Telephone records must demonstrate the

development of firm-client relationships and verify compliance with regulatory obligations as well as

detect and prove the existence of market abuse

Investment recommendations (MAR Article 3.1): A recommendation’s/strategy’s ‘history’ will need to

be included, as will a history of recommendations made for that particular issuer or instrument – an

incredibly difficult task. How do you keep track of all conversations which may have contained a

recommendation? Where a recommendation is made using extracts from another recommendation, or

when it is altered from the original, this must be made clear to the recipient, and there should be no

attempt to mislead.

Conflicts of interest (MAR Article 8 and 10): Any conflicts of interest will need to be disclosed, together

with a description of any ‘Chinese walls’ designed to prevent conflicts of interest.

Intent (MAR Annex II Section 1): Firms will need to record to identify possible fraudulent behaviour and

any failure to reproduce requested data will result in penalties.


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5 Implementation challenges

5.1 Tracking and analysing MiFID II is an enormous piece of regulation which to date encompasses over 1.4 paragraphs of

obligations cut across 3 levels of regulatory tools; legislation, technical standards and supplementary

guidance. Communications as a topic is effected by a broad range of the obligations across disparate

topics such as trading, governance and investor protection. There tracking and analysing the collective

requirements and implications on communication is a tough task.

5.2 National transposition Due to the implications of MiFID II and MAR being split between a Directive and a Regulation at the

legislative level (i.e. rules within the Directive will be subjected to national transposition) each national

jurisdiction may employ differing rules on the recording of telephone and electronic conversations.

5.3 3rd country complications The application of MiFID II and MAR on an extraterritorial basis (i.e. outside of the EU) causes

complications and conflicts with certain domestic data protection laws. For example, there many Asian

jurisdictions which have data protection laws which clash directly with MiFID II data retention

requirements for client data. Firms will need to manage this legal conflict.

5.4 Extraterritorial application MiFID II and MAR contain a complex web of extraterritoriality rules which govern how the MiFID II rules

apply to non-EU firms. Communication recording rules apply in instances in which the investment firm is

within the EU. This means that the rules not only apply to EU investment firms, but also to EU branches

and subsidiaries of non-EU investment firms. In other areas of MiFID II and MAR requirements that rely

upon communications recording, such as monitoring for market abuse apply globally to EU firms,

therefore capture any non-EU branches or subsidiaries of EU investment firms.

5.5 Interdependencies There are a vast number of other record keeping requirements spread across other regulatory initiatives,

for example EMIR, Dodd-Frank and GDPR. Doing regulatory reform regulation-by-regulation is tough -

the requirements are too many and doing them one-by-one wastes time and requires you to change

course every time a new capability requirement is identified

5.6 Digitisation of voice trading MiFID II requires that, for Systematic Internalisers, on a pre-trade basis for orders which meet certain

criteria (e.g. liquidity and volume) that a quote be made available to all client before it may be executed

with the original requestor. It also prohibits trading in products which have profiles with certain

requirements. This requires that an order be subject to a ‘eligibility checking engine’ prior to execution to

determine its trading eligibility and pre-trade obligations, creating a problem for voice trading, and it is

considered too time consuming to enter the required detail manually. A significant technical challenge is

digitising such voice quotes in a timely and accurate manner to be able to meet these requirements.

5.7 Keeping records of unexecuted orders Firms are obligated to keep records of unexecuted order under MiFID II which requires functionality that

typically does not exist within firms today.


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5.8 Use of mobile phones within firms Although the policy which employing a policy that bans the use of mobiles may technically cover the

obligation, it may not work from a compliance perspective and that national competent authorities may

still request these records.

5.9 Trade reconstitution In order to demonstrate compliance to a regulator under MiFID II a firm can be asked to reconstitute the

full life cycle of a trade from order to execution. This will rely on being able to retrieve and match

communications records. Firms are grappling with questions of how they will record events, trades,

transactions and all types of communication accurately enough in order to be able to do so in a timely

manner.

5.10 Flexibility on formatting of records Not being compliant with the specified formats required under MiFID II, would result in a large technology

impact. Although firms can use any medium they would have to use the prescribed format at the time of

reporting. Therefore, building a bridge between the two formats would form an added level of complexity


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6 Implementation approach

The initial challenge in implementing something as large and impactful as MiFID II is how to structure the

program. As a useful guide, the below reflects a typical MiFID II program;

Market structure. A work stream to cover the new market infrastructure. Key standards include

how to operate like and identify Systematic Internalisers (SIs) and how to consume consolidated tape

(CTP) data.

Trading. A way to manage new rules relating to trading. Key standards include how to identify

algorithms and what kind of microstructural controls will meet operational risk’s needs.

Reporting. The mother of all data management challenges. Key standard challenges include what

is reportable, who reports and how and how to fill in the fields.

Investor protection. A work stream focused on improving fairness and conditions for customers and

investors. Key standards include more client classification, financial promotions and new best

execution rules.

Governance. Includes requirements relating to governance and structures. Key standards include

new record keeping requirements and new authorisation rules. This work stream is also primarily

based on text from the directive.

For MiFID II and other interdependent regulatory regimes firms will rapidly need to:

Review current and incoming regulatory changes and understand which are relevant to their

business models and how to apply them,

Inform clients of the coming changes and repaper them accordingly.

Implement new policy and on-boarding frameworks.

Implement the appropriate IT systems to support each requirement.

Align reference data suppliers (internal and external sources).

Turing specifically to the challenges specific to the obligations which impact communications related

requirements there are 4 stages to the implementation process:

Scope and strategy: Identify the problem and interpret the requirements. What is it that the new

regulation requires and what is our strategy for achieving this? This can be carried out by legal

functions or external council?


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Detailed requirements and planning: What are the detailed requirements and where are the gaps

in terms of what we currently undertake? This can be carried out by compliance and technology

functions or external consultants.

Organisational responsibilities: Who is responsible for this within the organisation and where will

this activity be carried out? This can be resolved by compliance functions or external consultants.

Technical solutions: How do we meet the requirements, what formats and structures do we need?

This is the challenging aspect and the question here is can we build something internally or is this

something that we need to go out to market for?

Ultimately within each of these stages there are 4 key challenges to get right:

Policies and procedures: Do all the required policies currently exist? Where are the gaps and do

the existing policies include all the information it is necessary to capture?

Applications: Do they capture all the data that must be captured and store it in a format that will

allow reconstitution at any time in the following years?

Data: Is everything captured? Are there any risks related to the capture, storage and retrieval

processes?

Infrastructure: Will the growth of each set of data be accommodated by the current infrastructure?


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7 Conclusion

Considering the large expenditure that firms are likely to face within this space, firms should consider

focusing on implementing in the most efficient way possible, getting MiFID II right the first time, otherwise

even larger budgets will be needed to tweak new policies and recalibrate new systems builds. Ultimately

firms should be looking to leverage this spend to not only successfully meet the requirements but also to

enhance the business decision making and the client experience. Considering the changes that MiFID II

will impose on technology, affected firms will be carefully determining their implementation measures and

will be considering technology solutions.

One of the available technology solutions today is NICE COMPASS, a comprehensive solution to

address all of the MAR and MiFID II challenges for communications compliance. NICE COMPASS

combines omnichannel recording with automated compliance assurance, and combined with NICE

Communications Surveillance can help firms ensure complete compliance across the enterprise.

Some of the key capabilities of NICE COMPASS are:

Omnichannel recording, search and replay

Enterprise-wide omnichannel solution for recording turrets, mobile phones, PBX (desk phones), and

Unified Communications (e.g. Skype for Business, Cisco Jabber), enabling complete reconciliation and

reconstruction of all communications at each stage of the trade transaction lifecycle. Firms can also set

configurable retention periods for different asset classes, lines of business, and regulated user groups, to

comply with specific global and/or regional regulations for records retention. The solutions has a

centralized portal and search engine that compliance managers can use to find all communications

related to any trade or transaction.

Compliance assurance

NICE COMPASS goes beyond recording to provide evidence of compliance, another key requirement of

MiFID II. It monitors recording processes through scheduled, automated health checks that test for

network, gateway, PBX, recording, audio quality, archiving, and retention anomalies. NICE COMPASS

also simulates calls to ensure that regulated personnel are recorded and that recordings are properly

retrained -- auditing, documenting, and reconciling every step for evidence of compliance. A compliance

assurance dashboard makes it possible to visualize real-time recording compliance status across the

enterprise. In addition to the dashboard, NICE COMPASS offers automated reports for compliance

personnel which provide a step-by-step reconciliation of the entire recording lifecycle for evidence of

compliance.

NICE Communications surveillance

Market abuse can result in huge fines and damage a firm’s reputation. To counter this risk, financial

institutions monitor communications, but they often resort to manual methods which are cumbersome and

time-consuming. NICE Communication Surveillance saves time and minimizes risk by using advanced

speech and behavioural analytics to monitor 100% of trade-related interactions across all communication

modalities, to detect potential market abuse and complies with the Market Abuse Regulations (MAR).


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Communication Surveillance 3.0 – <Document Title>

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ABOUT NICE

NICE (NASDAQ: NICE) is the worldwide leading provider of enterprise software solutions and is bringing about The End of Not Knowing

by generating insight based on advanced analytics of structured and unstructured data. NICE solutions help the world’s largest

organizations deliver better customer service, ensure compliance, combat fraud and safeguard people. Over 25,000 organizations in more

than 150 countries, including over 80 of the Fortune 100 companies, are using NICE solutions. More info on www.nice.com.

ABOUT NICE FINANCIAL COMMUNICATION COMPLIANCE

Financial Communication Compliance is a significant business line within the NICE organization and focusses on delivering new

technologies to facilitate regulatory requirements. NICE is a leader in the RegTech market, serving the largest financial services

organizations globally. These compliance solutions respond to an increasing demand in the financial services market, where regulatory

compliance is on the rise. NICE is focused on the communication compliance market and has together with NICE Actimize an unmatched

presence in the domain of Holistic Surveillance. More info on www.HolisticSurveillance.com.

ABOUT JWG – MAKING SENSE OF FINANCIAL REGULATIONS

JWG are operations and technology professionals, trusted by the global financial services industry as experts in regulatory change

management. For the past decade, a team of independent analysts has helped the industry interpret large quantities of regulatory reform

and action it in a smart and intelligent way. More info on www.jwg-it.eu

CONTACTS

Global International HQ, Israel EMEA, Europe & Middle East

T +972 9 775 3777 T +44 0 1489 771 200

Americas, North America Asia Pacific, Singapore Office

T +1 201 964 2600 T + 65 6222 5123

NICE Financial Markets Communication Compliance

[email protected]

The full list of NICE marks are the trademarks or registered trademarks of Nice Systems Ltd. For the full list of NICE trademarks, visit http://www.nice.com/nice-trademarks all other marks used are the property of their respective proprietors.

Copyright © 2017 NICE Financial Communication Compliance. All rights reserved.

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the impact of mifid ii and mar on communications compliance · 2019-02-15 · the impact of mifid...

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