The one year delay to the implementation of MiFID II provided the industry with some welcome respite from the seemingly unrelenting waves of regulatory reform. European regulatory implementation timetables are always tight but the original MiFID II timetable was proving to be unrealistic for both the regulators and the regulated. But time is quickly passing and the recent publication of all three Level 2 delegated legislation served as a sharp reminder that the asset management industry, along with others, is reaching a critical time on the road to the new effective date of MiFID II.
Given the breadth and complexity of the MiFID II reforms, and the consequential changes required to IT/systems and wide-scale document repapering, many managers are likely to be approaching the point when they need to accelerate their implementation projects to be ready on time. The results of initial scoping exercises and gap analyses will need to be converted quickly into detailed implementation action plans across all of the impacted parts of the business.
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