Dear Santa…a MiFID II Christmas wish list
I have been very good this year. I planned my MiFID II transaction reporting project early. I read Levels 1, 2 & 3 (well maybe not all of level 3…). I put enough money in the budget, identified my risks and spoke to my peers. In short I think I have done everything possible but I still think I might be in a little bit of trouble. So this year for Christmas I have one or two wishes that I hope you can grant so I can start the new year with a cheery grin as big as yours.
Could you and Ruldolph please drop into my stocking this year:
- An LEI for all my clients who are refusing to get one even though I have offered to help many times in doing so. I do want to keep talking to them next year!
- Help trading venues send the fields they need to for me to make my report.
- May my ARM be able to onward report to the FCA without any issues.
- A bright and sparkling new reconciliation that reconciles all my trades and not just the ones I sent
- Change ESMA’s mind and let them agree that the FIRDs list is a golden source of data
- Please just make ‘shortselling’ either go away or send me a new magical toy that will calculate it every day and correct it even after I need to include a trade that was not captured the previous day
- Some really clever testing that identifies any of my mistakes so I can tell my Senior Manager Regime (SMR) manager all is well and he/she won’t lose their house
- Make all corporate actions involuntary even though they aren’t (our secret, Santa)
- Now I have lots of friends from different countries and I would like just one way of identifying them not several.
- An Xbox with the latest version of Overwatch
Now Santa I hope you don’t think me too greedy, but compared to my friends in America and Hong Kong I think I might be in more need for Christmas presents than them.
I’ll leave a mince pie for you and some carrots for Rudolph . Even if you can send me a few of the items I have asked for, I will be happy and I promise I’ll ask a lot less for next year.
P.S If you can’t do 4 and 7 then please drop this letter over to those lovely people at Kaizen Reporting, I am sure they will be able to help!