FEATURING Abide Financial // AQMetrics // BT smartnumbers // Complymatic // Digiterre // netConsult // RFA

TECHNOLOGY Implications, challenges and solutions

REGULATION Constructing a solid regulatory compliance framework

PREPARATION Applying the accurate amendments

M I F I D I I 2 0 1 6WEEKHFM

S P E C I A L R E P O R T

THE TECHNOLOGY PARTNER TO THE FINANCE SECTOR

TRUSTED TECHNOLOGY PARTNER

WWW.RFA.COM T +44 207 093 5010 E gralph@rfa.com

RFA has been the trusted partner to hedge funds for over 25 years.

Focused on excellent service with a commitment to provide industry-leading

technology solutions designed to meet the specifi c requirements of the sector.

Long term, trusted advisors to over 530 clients across the globe.

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H F M W E E K . CO M 3

Published by Pageant Media Ltd LONDONThird Floor, Thavies Inn House, 3-4 Holborn Circus, London, EC1N 2HAT +44 (0) 20 7832 6500 NEW YORK 200 Park Avenue South Suite 1603, NY 10003T +1 646 891 2110

his HFMWeek report focuses on the impending implementation of Mifid II, how to adequately prepare and the effects it will have on the industry.

Despite delays, Mifid II will bring in a number of requirements when it finally arrives and back office, compliance and IT teams will need to work in unison in

order to ensure full compliance with the directive. The legislation is set to have major technological implications around areas such as reporting, transparency of trading costs and recording calls.

The contributing individuals to HFMWeek’s Mifid II Report, deliver an insightful examination of one of the biggest and most extensive regulatory changes to be implemented in recent times.

Tom SimpsonReport editor

T

REPORT EDITOR Tom Simpson T: +44 (0) 20 7832 6535 t.simpson@pageantmedia.com HFMWEEK HEAD OF CONTENT Paul McMillan T: +1 646 891 2118 p.mcmillan@pageantmedia.com HEAD OF PRODUCTION Claudia Honerjager SUB-EDITORS Luke Tuchscherer, Mary Cooch, Alice Burton, Charlotte Romeyer ASSOCIATE PUBLISHER Lucy Churchill T: +44 (0) 20 7832 6615 l.churchill@hfmweek.com HEAD OF BUSINESS DEVELOPMENT AMERICAS Tara Nolan +1 (646) 891 2114, t.nolan@hfmweek.com PUBLISHING ACCOUNT MANAGERS Alex Roper T: +44 (0) 20 7832 6594 a.roper@hfmweek.com; David Butroid +44 (0)207 832 6613 d.butroid@hfmweek.com; Alexandra Bethanis T: +44 (0)207 832 6618, a.bethanis@hfmweek.com THE MEMBERSHIP TEAM +44 (0) 20 7832 6511 membership@hfmweek.com CIRCULATION MANAGER Fay Muddle T: +44 (0) 20 7832 6524 f.muddle@pageantmedia.com CEO Charlie Kerr

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I N T R O D U C T I O NM I F I D 2 0 1 6

4 H F M W E E K . CO M

M I F I D I I 2 0 1 6 C O N T E N T S

TECHNOLOGY

HOW WILL MIFID II CHANGE DATA?Managing director of RFA UK, George Ralph, examines the technological implications of Mifid II and the radical amendments data will be subject to

COMPLIANCE & REGULATION SERVICES

ARE YOU READY FOR MIFID II?Chris Dingley, head of sales at Abide Financial, discusses the significance of Mifid II preparation

TECHNOLOGY

MIFID II’S TECHNOLOGICAL IMPLICATIONS AND CHALLENGESPhil Ashley of netConsult investigates how Mifid II is set to restructure the use of technology and how to overcome any impending obstacles

TECHNOLOGY

CLOUD-BASED COMPLIANT CALL RECORDING AND STORAGEJames Foley of BT smartnumbers explains why it is important to shift from traditional to cloud-based administration techniques

FUND MANAGEMENT

WHAT YOU NEED TO KNOW ABOUT MIFID IIGeraldine Gibson, CEO and founder of AQMetrics, examines the background of Mifid and offers insight into how to adequately prepare for the implementation of Mifid II

LEGAL

THE NEED OF A ROBUST REGULATORY COMPLIANCE FRAMEWORKDr Pinar Emirdag, of Complymatic, emphasises the significance of constructing a solid regulatory compliance framework

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6 H F M W E E K . CO M

M I F I D I I 2 0 1 6

George Ralph is managing director of RFA UK. He is a technology and business leader with a proven track record of strategic alignment, process implementation, streamlining work flow and improving delivery. He has successfully founded three technology firms, implemented C level roles and strategies at numerous firms and has over 16 years’ technical experience in network and server architecture, large scale migrations utilising leading technology brands and IaaS offerings.

HFMWeek (HFM): Th e draft of Mifi d II technical standards were published in December 2014, what can banks and capital market institutions do in terms of preparation for Mifi d II?George Ralph (GR): Th ere are two major challenges when it comes to preparation. First of all, preparing peo-ple for the inevitable, there are a signifi cant number of people who are not doing anything due to an expectation of continuous delays. Th e second being the unknown, Mifi d II is yet to be fi nalised, it is subject to relentless changes and we have not seen a nailed down and con-crete form yet.

When Mifi d II was fi rst announced, we released a successful fi ve-step guide, this guide was from a techni-cal standpoint and highlighted a number of factors to support organisations. Th e fi rst point was really helping organisations understand, one, what the actual scope of work is in order to fulfi l the requirements. Two, to identify gaps in their current com-munications infrastructure. Th ree, to identify data retention requirements (if it can’t be compressed, what im-pact it has on costs, security, storage techniques). Four, to work out their data lifecycle management (how are they going to store the data, are there any SLAs they need to think about in terms of the retrieval of the data, how the data moves throughout the life-cycle), and fi ve, fi nd a trusted partner to help plug any gaps.

HFM: What are the major tech-nological implications presented by Mifi d II? And how can they be overcome?GR: Th ere are a range of views in regards to technologi-cal implications; there are technical implications from a infrastructure perspective and technical implications for the kind of recording methods used i.e. face-to-face meetings, text messages, mobiles and landlines and also the changes in customer reporting, for example the clas-sifi cation methods. One of the biggest challenges we are going to be witness to is not just where to store the data, but how to report quickly on the transactions against multiple fi le types, as there has been an estimate of a fi ve minute window for transaction reporting. An example of issues surrounding reporting, you may have a mobile recording which is a wav fi le and then a landline record-ing which is a wav fi le, but are both probably saved on

diff erent systems, additionally, you may have a text fi le from SMS. Alongside this, you may be conducting face-to-face meetings and you have to digitalise the minutes, that’s another format, how do you report on all of those in one place when they all have diff erent fi le types? Th is is certainly the most challenging obstacle presented by Mi-fi d II, and as to date I am yet to see a product that amal-gamates ‘all’ of these fi le types in a sensible and secure fashion.

HFM: How important will be launching or recon-fi guring a customer-facing portal to increase client interaction?GR: Th is is going to be extremely important because of transaction reporting, the whole wording of the data clas-sifi cation type is going to be taken very diff erently by dif-ferent people. Th ere aren’t many investor reporting tools out there that can be used straight off of the shelf, they

have all had to have been customised one way or another, or developed on their own.

You are essentially going to change the metadata of all of your client’s information on your reporting tool, the solution to this will be to either employ someone to sit and update all the data, or you are going to au-tomate the change to classify. In terms of the customer facing portal and what we are reconfi guring it to make it easier to use for the inves-tor to view and what is happening in the space of the clients, I think that’s not necessarily challenging, because most people will have outsourced

development if they’ve already customised it. In order to off er the right levels of protection to the right clients, a robust client classifi cation and related client data reposi-tory should be built and maintained. Many fi rms have something like this in place, but Mifi d II will add new data att ributes and will amend others. I think that’s one of the things that will change quite drastically before it is actually fi nalised.

HFM: What technological implications will Mifi d II have on data?GR: It’s all about data and the major issue is stage one i.e. how we store it all. If you are recording landline calls, texts, mobile calls, etcetera, you are going to be accumu-lating a tremendous amount of data. I’m not sure whether

YOU ARE ESSENTIALLY GOING TO CHANGE THE METADATA OF

ALL OF YOUR CLIENT’S INFORMATION ON YOUR

REPORTING TOOL

”

HOW WILL MIFID II CHANGE DATA?

MANAGING DIRECTOR OF RFA UK, GEORGE RALPH, EXAMINES THE TECHNOLOGICAL IMPLICATIONS OF MIFID II AND THE RADICAL AMENDMENTS DATA WILL BE SUBJECT TO

T E C H N O L O G Y

H F M W E E K . CO M 7

the smaller hedge funds will be able to do it economically, potentially, it will force some of the less successful hedge funds to consider using incubation type firms more. The second challenge will be reporting against the data, the fact is that there will be a selection of different data types stored in different locations, so unless someone comes up with a unique database that allows you to store different data types, then this will certainly be a big obstacle.

HFM: How will transparency reporting affect the industry?GR: The whole point of Mifid II and Mifid I is to im-prove ‘market integrity’ by making trading activities more transparent. In terms of transparency affecting the industry, I don’t think it will have a massive affect, as we are all doing a lot to prove the integrity in the space. It will continue to protect investors, as it will provide them with even more information than they have now, which should hopefully give them to ability to make more in-formed decisions. It also adds protection the other way

as firms can prove what they were requested to do. For example, if an investor calls and says: “Put this amount of money on this fund,” and that’s not recorded, and then call back a year later and say “well I didn’t actually ask you to do that I meant the other one,” this will massively reduce the chances of this happening.

HFM: What will happen to the banks and capital mar-ket institutions that do not prepare adequately when Mifid II arrives?GR: The whole point of Mifid II is not just to be a compli-ance exercise. It is not simply about adding another level of regulatory control, there are also major strategic implica-tions. Although, it can additionally bring market opportu-nities and if firms get it right early on, it could potentially give them a bit of a competitive advantage in the future. If people don’t adhere to Mifid II and therefore don’t meet the requirements, they’ll lose revenue as they will be fined. At the end of the day, if they don’t do it, it’s going to cost them money and potentially investor security.

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M I F I D I I 2 0 1 6

Chris Dingley is head of sales and is responsible for ensuring Abide Financial clients are among the top performing reporting firms. Having graduated with an MChem from Durham University, Dingley has held a number of commercial and product management roles in the financial services industry.

HFMWeek (HFM): How important is preparation in the wake of Mifi d II?Chris Dingley (CD): With the implementation date of MiFIR confi rmed, fi rms can now plan in earnest to imple-ment new transaction reporting processes that will, by any measure, be more taxing than those imposed by EMIR.

While in principle transaction reporting should be a simple subject, in reality the devil is very much hidden in the detail, with edge cases accounting for many breaches and internal translation errors leading to inaccurate data being reported.

Th e fi nance industry as a whole has been digesting the Level 3 guidance issued by ESMA and the FCA in late 2016. Within this, there is good news with regard to the de-scoping of AIFMs and Ucits from the reporting requirement – the FCA is not proposing to re-implement super-equivalence de-manded in Mifi d I. However, many hedge funds undertake Mifi d busi-ness and the increased product scope of MiFIR (commodities, FX derivatives and many basket trades) will drag more fi rms into reporting scope.

For those in reporting scope, it is worth fl agging that a direct extension of the delegated report-ing model created under EMIR, is very unlikely. MiFIR calls for the capture of personal details and identifi ers, such as national insur-ance numbers for UK citizens, and dealers will be very wary of maintaining this data in their own networks. Secondly, fi rms may be constrained by the reporting rules themselves: MiFIR envisages that fi rms who engage only in the receipt and transmission of an order (RTO) will not need to report transactions. However, the latest ESMA pa-per expressly excludes this option for a fi rm executing in a principal capacity and imposes strict conditions for es-tablishing that RTO has been performed in all other cases.

HFM: Why might initial preparation be harder than you think?CD: Once a fi rm has established that it needs to report, it needs then to begin to understand the internal impacts of MiFIR reporting. For example, where a fi rm conducts Mifi d and non-Mifi d business, it must be able to ensure that only Mifi d eligible trades are reported. Th is could

require extensive work to understand exactly what trades are generated from which book. Similarly, block orders may be allocated across multiple books, and transaction reporting needs to refl ect this in a purely Mifi d context.

Trading with non-EEA counterparties also causes re-porting concerns: it is important for market participants to understand that Mifi d reporting obligations extend be-yond EU/EEA borders. For example, any derivative trad-ed outside of the EU, where the underlying instrument is traded on an EU trading venue, must be reported and fi rms executing orders ‘off shore’ for dual listed instruments for an EU-based decision maker may have to provide an LEI to submit trade reports to the EU entity – and in a format compatible with that entity’s own transaction reporting

process. Newer regulation also advances the control requirement imposed on fi rms. In the case of MiFIR, this is writt en into the Level 2 text (the methods and ar-rangements for reporting fi nancial transactions) and encompasses a raft of reconciliation and assurance requirements. Firms now become liable for identifying and correcting instances of over – and under-re-porting, reconciliation of all report-ing for timeliness, completeness and accuracy and for identifying errors and omissions in transaction reporting.

Th e industry also faces external challenges in the timeline and com-plexity of transaction reporting. Mandating of ISIN identifi ers for all products traded on trading ven-ues and their equivalents is subject to much discussion and their cre-

ation, dissemination and accuracy will be key to meeting the completeness and accuracy demands of the regulation. Indeed, the challenge of timely collection of this data and subsequent calculation of liquidity baskets, trade publica-tion delay criteria, double volume cap metrics and the like has been the principal cause of ESMA’s delay in imple-menting the regulation.

HFM: What is happening in the industry?CD: Brokers are now in the process of assessing how they might support clients for MiFIR, with the majority making fi rm decisions that they cannot support the provision of delegated reporting services. Th eir reasoning is being driv-en primarily by their unwillingness to support sensitive

ARE YOU READY FOR MIFID II?

CHRIS DINGLEY, HEAD OF SALES AT ABIDE FINANCIAL, EXAMINES THE SIGNIFICANCE OF MIFID II PREPARATION

SPECIALIST KNOWLEDGE REQUIRED TO ENSURE

REGULATORY COMPLIANCE IS IN SHORT SUPPLY DUE TO THE UNPRECEDENTED

EXPANSION OF REPORTING PARAMETERS

”

C O M P L I A N C E & R E G U L AT I O N S E R V I C E S

H F M W E E K . CO M 9

personal data in their reporting systems, and associated potential liabilities created against entities and individuals many steps away in the transaction chain.

On the traditional buy-side, many firms have reached the conclusion that they will need to self-report under Mi-FIR, requiring the implementation of a reporting and con-trol structure to support all MiFIR requirements. As part of the process of analysing self-reporting requirements, many firms are also reappraising delegated reporting pro-cesses for EMIR, not least because the cost benefits of delegated reporting have not been proven in application. In fact, monitoring compliance through multiple vendor GUIs and broker interfaces is proving to be complex and inefficient. It is also the case that while businesses struggle to keep pace with the size and complexity of regulatory change, at this point in time delegated reporting providers can not all guarantee compliance.

With EMIR Reporting v2, MiFIR and SFTR all driving reporting change in the next 30 months, these businesses are actively exploring taking full control of reporting and accepting the responsibility imposed by the regulation.

HFM: What role do service providers have to play in Mifid II?CD: The prevailing service model in the reporting indus-try clearly does not meet the transaction reporting needs of most firms in 2016. The Trade Repository, Approved Reporting Mechanism or other mechanism accepts trans-action reports but does little more than validate these for data field conformance.

Clients are increasingly demanding visibility of the full lifecycle, report delivery timeliness, reconciliation of re-ports from source systems and deployment of reporting hubs that actively support the decision making process. This is driving adoption of a new model in reporting provi-sion where reporting delivery and assurance is delivered as a core component of the service model.

The relatively recent and unprecedented expansion of transaction reporting parameters (and obligations) means that the specialist knowledge required to ensure complete

and continuing reporting compliance is in short supply. There is a race for talent in this space in recognition of the fact that resources will be even more constrained by the end of 2016. As such, many firms may look to external con-sultancies.

Full service transaction reporting providers can better support the demands of system integration, apply logic-based rule sets, deliver reports to the end point, manage exceptions and provide the rigour of ongoing consultancy and advisory on evolving regulations to keep the reporting counterparty safe.

HFM: How does Abide Financial help reporting par-ties manage the challenge of Mifid II?CD: Understanding and managing the complexity of new reporting obligations under Mifid II/MiFIR – and with the proposed EMIR rewrite and other evolving regula-tory frameworks like SFTR thrown into the mix – presents an enormous challenge to all reporting firms, particularly those entities that find themselves subject to new regula-tory reporting obligations for the first time.

Eligible firms must determine whether they have suf-ficient expertise to evaluate evolving reporting require-ments effectively themselves and the right resources to expand or adapt internal systems and processes to deploy an effective and compliant solution to multi-regime, multi-jurisdiction transaction reporting obligations.

Many firms have chosen to partner with Abide Finan-cial – a specialist provider focused exclusively on under-standing and managing the impact of regulatory change on transaction reporting processes, and a reporting infra-structure that supports end-to-end reporting for multiple regulatory regimes and reporting destinations.

Specifically, Abide Financial’s PROXIMITY programme combines a systematic and guided approach to meeting regulatory reporting timelines with an established and effi-cient, end-to-end implementation, technology, operations and compliance ecosystem that helps all reporting parties manage the challenge of Mifid II/MiFIR, the EMIR rewrite and other regulatory reporting obligations.

T E C H N O L O G Y

H F M W E E K . CO M 11

M I F I D I I 2 0 1 6

Phil Ashley is the chief information officer at netConsult. A trained analytical scientist, he has more than 15 years’ senior IT experience across a range of industries, spending several of them running internal IT teams and as an external IT service provider in the finance industry.

HFMWeek (HFM): When should organisations be thinking about the technology requirements of Mifi d II?Phil Ashley (PA): Until recently, Mifi d II was set to gener-ally apply within member states by 3 January 2017, how-ever it is now expected that the European Commission will propose to delay its introduction by at least 12 months. However, this should not lead to complacency by aff ected fi rms. Although, at fi rst glance, many of the requirements may appear primarily on the compliance and client-facing side, there are potentially demands on technology which may be far greater than initially expected. Even with the proposed delay, these are relatively short timescales and organisations should consider preparing themselves at this stage by establishing strategies to comply with new regulations. Implementing Mifi d II from a technology perspective could require extensive eff ort, both in terms of planning and execution, so the sooner an organisation can begin preparing for this, the bett er.

Well-prepared and focused organisations tend to be ahead of the curve and have been thinking about the po-tential impacts on technology for the Mifi d II require-ments for some time. Some organisations may not have started any planning or analysis yet as they are waiting until all the fi nal details are in place – some of which are still under debate – and have been communicated by rel-evant authorities. Th e latt er approach can be dangerous, as it could result in not having enough time to implement suitable tools, procedures and processes in time to meet regulatory deadlines. Th is can also be costly as there might not be suffi cient time to carefully select the best choices

for the organisation. Uncertainty remains around the de-tails of Mifi d II, however the intentions are clear that au-thorities are aiming to bring additional regulation to the European fi nancial space.

HFM: How should organisations plan for Mifi d II im-plementation, in terms of their existing IT capabilities?PA: Given the breadth and detail of the Mifi d II require-ments, it is key for the business, compliance and IT teams to work together to fully understand the implications of complying. Carrying out a detailed risk analysis, mapping out processes and procedures required under Mifi d II, and then determining if existing IT capabilities and solutions will be adequate or can be adjusted provides a good start-ing point. If an organisation determines requirements to procure and roll out new tools and processes, or improve existing ones, then having started this all sooner rather than later will give organisations the time to engage with vendors as soon as possible and go through a well thought out procurement process, including negotiating terms with preferred vendors.

Documenting and retaining this risk analysis is key to providing an audit trail of the decision process, when an organisation decides what part of the regulation applies to their business and if the tools and processes are eff ective as well as suffi cient in order to meet the regulatory require-ments. Without risk-based decision-making, working to tight deadlines under regulatory scrutiny may result in IT and compliance teams hastily making decisions that may be regrett ed in the future as they determine and procure the tools and processes for years to come.

MIFID II’S TECHNOLOGICAL IMPLICATIONS AND CHALLENGES

PHIL ASHLEY OF NETCONSULT INVESTIGATES HOW MIFID II IS SET TO RESTRUCTURE THE USE OF TECHNOLOGY AND HOW TO OVERCOME ANY IMPENDING OBSTACLES

T E C H N O L O G Y

1 2 H F M W E E K . CO M

M I F I D I I 2 0 1 6

HFM: What are some of the key requirements and de-mands the proposed regulations place on technology?PA: There are various key points in the current Mifid II proposal that have a direct impact on technology. While there is still some ongoing industry debate about the tech-nological requirements, it is important for organisations to have a clear technology strategy in place.

There is an obligation in Mifid II requiring organisations to keep records relating to all services, activities and transactions, intended to result in transactions and client order services, even if the transactions or ser-vices are not concluded. This means the recording of telephone conversations, face-to-face meetings and electronic communications relating to actual or proposed transactions, as well as informing cli-ents that conversations and communications will be recorded. These records must be provided to the client upon request and kept for several years, so merging and cohesively recording all communica-tion mediums will enable organisations to meet the requirements of presenting a consolidated review of client interaction, potentially delivered through client portals.

This does present some technical challenges, particularly around telecommunications. Solutions are available from mobile applications to network provider services and SIM cards. There are advan-tages and disadvantages to all of these, however considering what current IT solutions can sup-port and what additional benefits the organisation could gain from implementing a solution should factor in the decision making. These do normally predicate an organisation having ownership and control over the systems and technology being used and subsequently, or-ganisations will have to consider taking reasonable steps to prevent telephone conversations and electronic communi-cations on privately owned equipment that the organisa-tion is unable to record or copy.

Mifid II will also introduce the requirement for trading venues and their members and participants to synchronise the business clocks used to record the date and time of reportable events to UTC (co-ordinated universal time). This will also require an adherence to a maximum permit-ted divergence from UTC, which can vary from organisa-tion to organisation depending on the nature of the actives and latency times.

The challenge of time synchronisation across IT systems is not a new one, however the Mifid II mandates are quite substantial, particularly with high-frequency algorithmic trading techniques aiming for a maximum UTC divergence of 100 microseconds. Once organisations do achieve this however, significantly more accurate timings are available

when generating reports, performance statistics and recon-structing trades, providing considerable insight into ways to oversee and further enhance the trading process.

Options are available when it comes to selecting a time source, notably a country’s official timing centre or via sat-ellite GPS system. While even these sources can vary by up to 20 nanoseconds, as UTC itself is an average of all the participating clocks, the real problem faced by organi-

sations lies in the number of points where diver-gence can occur. Consider that a distance of just 50m of cable from a roof antennae could add up to 300 nanoseconds, data network switches could add one to two microseconds per device and ap-plications could face delays in getting the time from an operating system which could be dealing with billions of other requests in any given second. Meeting the Mifid II mandates would require very high levels of synchronisation, potentially across multiple datacentres and countries, which is likely to be a complex and costly exercise along with very careful consideration as to all elements that could introduce inaccuracies.

A final point to discuss is with regards to al-gorithmic trading organisations. Under Mifid II, the decisions to transact at a certain price, time or quantity should be made with little or no human intervention. A number of provisions in Mifid II exist with regard to the comprehensiveness of the testing process before algorithms are released into a production environment, with indications that test packs, trade populations and environments should

be reviewed for regulatory compliance before every release. Keeping formalised test environments has been common practice for some time; however, further scrutiny is now coming from these regulations. Organisations may need to provide appropriate environments to test algorithms before release and identify orders generated by algorithms.

HFM: Are there any impacts on cyber-security from Mifid II? PA: While the Mifid regulations primarily cover the trading process, and the governance around it, there are elements that require an organisation to have security mechanisms in place. Guaranteeing the security and authentication of the means of transfer of information, minimising the risk of data corruption and unauthorised access, and prevent-ing information leakage in order to maintain confidential-ity. Ultimately, increasing the amount of data governance around a business process can intrinsically improve its security when the security of systems or processes imple-mented as part of Mifid II compliance is considered as part of a risk-based development plan. 

WELL-PREPARED AND

FOCUSED ORGANISATIONS TEND TO BE AHEAD OF THE CURVE AND HAVE BEEN THINKING ABOUT THE POTENTIAL IMPACTS

ON TECHNOLOGY FOR THE MIFID II REQUIREMENTS

FOR SOME TIME

”

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1 4 H F M W E E K . CO M

M I F I D I I 2 0 1 6

James Foley is VP – customer experience at BT smartnumbers, responsible for outstanding customer relationships and service. James spent eight years as VP of the banking sector at BT smartnumbers, working very closely with leading investment and retail banks to underpin organisational agility, resilience and compliance.

In the near 500 pages that the European Parliament uses to describe the new regulatory regime under Mifi d II, fund managers could be forgiven for over-looking Article 57, a short section that covers the increased need for fi rms to have their business tele-phone calls recorded.

Many fi rms will already record calls, since from 2011 the FCA has required that UK trading fi rms record land-line and mobile calls. However, under Mifi d II, the scope and scale of this requirement is going to increase signifi -cantly, to the extent that it will for many require a funda-mental rethink of a fi rm’s overall call recording strategy.

Firms will overlook this at their peril. Regulators have shown themselves to be very unforgiving when it comes to a compliance oversight.

WHAT ARE THE NEW RULES?Th ere are already a number of rules regarding the record-ing of mobile conversations, some from the UK’s regula-tor, others from Europe and still others that cover data protection and human rights. Th e current FCA regula-tions covering call recording are found in the Conduct of Business manual, section 11.8, and mandate that anyone directly in the trading of equities, bonds, op-tions and futures should have their telephone and SMS

communications recorded and stored in a tamper-proof repository for a minimum period of six months.

Under Mifi d II, this expands to include not only those directly involved in trading, but anyone who is involved in the advice chain that may lead up to a trade, includ-ing those trading in commodities. In practice, this will cover all front-offi ce staff , including administrative staff and anybody who has any engagement with clients. Th e retention period for these recordings will increase to a minimum of fi ve years.

While these rules may present a set of challenges to fi rms, they are made even more complicated due to an-other set of EU regulations that come into force at the same time. At the end of 2017, the UK Data Protection Act will be replaced by EU regulation, known as the Gen-eral Data Protection Regulation (GDPR).

Th e GDPR prohibits, among other things, the re-cording of personal conversations on business phones – with a maximum fi ne for serious breaches rising from £500,000 ($710,000) to a potentially vast 4% of a fi rm’s total worldwide turnover. Providing staff with the conve-nience of being able to make the occasional personal call on a business mobile phone that is being recorded could expose the fi rm to signifi cant risk.

What sounds like a simple and straightforward

CLOUD-BASED COMPLIANT

CALL RECORDING AND STORAGE

JAMES FOLEY OF BT SMARTNUMBERS EXPLAINS WHY IT IS IMPORTANT TO SHIFT FROM TRADITIONAL TO CLOUD-BASED ADMINISTRATION TECHNIQUES

T E C H N O L O G Y

H F M W E E K . CO M 15

requirement – to record business conversations and store these securely for audit purposes – isn’t as easy as it sounds. This is in part due to technology constraints, but also due to the very nature of fund management and the work styles of today’s fund manager.

THE TECHNOLOGY CONSIDERATIONSLet’s deal with technology considerations first. While there are a number of solutions for recording landline calls, these tend to be expensive, require on-site equip-ment and dedicated IT resource (something many fund managers are light on). Furthermore, landline systems can’t record mobile calls, so many firms use the network-based call recording available from their mobile network, but this is expensive and can have issues with recording calls when the subscriber is roaming internationally.

There are a number of smaller boutique mobile call recording vendors, but these require that the firm uses a special SIM to record calls – with call tariffs usually many times the normal market rate. These also have issues with recording calls when travelling internationally. Call re-cording is complicated further by the increasing trend within firms to adopt flexible mobile policies, which al-low a single device to be used for personal and business calls.

Some firms have adopted ‘bring your own device’ (BYOD) as a convenience and productivity aid to staff, while others have adopted a ‘corporate-owned personally-enabled’ (COPE) policy, enabling staff to personalise corporate devices for their own use. In both cases, the intent is to enable a single device to be used for personal and business use – and in both cases the unintended consequence in potential non-compliance.

WORKSTYLE CONSIDERATIONSThe nature of fund management itself can present problems with achieving compliance due to a num-ber of factors. The first reflects the fact that fund managers can spend a great deal of their day not at a trading desk, but in meetings – inside or outside of the office. The implication of this is that fund man-ager’s calls are often handled by support staff, who themselves may be desk-based or mobile. Indeed, effective teamwork is often a differentiator in terms of the ability of the leading firms to provide the best client service. No matter where a call made to a fund manager is eventually taken – by the fund manager, their support staff or other delegates – it will need to be re-corded.

Secondly, fund managers running large international funds or a portfolio of international clients, will often spend a great deal of time overseas. We have touched on the technical implications of this with respect to record-ing calls when roaming, but the problem is increased as more people use WiFi clients such as Skype to reduce their call costs. No matter what device or network is used to make or receive the call, it will need to be recorded.

The third factor is that many fund management firms retain a very lean IT support operation and the recording of fixed or mobile phones presents a range of complexities. Together with the fact that the storage of these calls for

BT SMARTNUMBERS HAS BEEN DESIGNED TO MEET THE REGULATORY

OBLIGATIONS OF FINANCIAL SERVICES BUSINESSES, AND IS PARTICULARLY WELL

SUITED TO THE FUND MANAGEMENT SECTOR

”

a minimum of five years is mandated under Mifid II, it is clear that firms need an affordable, scalable, simple-to-im-plement and fully managed service that is fully compliant.

BT SMARTNUMBERS – A SERVICE FROM THE CLOUDThe good news is that it doesn’t have to be difficult or ex-pensive to meet these new regulatory requirements. BT smartnumbers has been designed to meet the regulatory obligations of financial services businesses, and is partic-ularly well-suited to the fund management sector. With more than 300 UK financial services sector clients, BT smartnumbers provides mobile call recording across all fixed and UK mobile networks. On mobile devices, firms can keep their SIM, network provider and phone number while still ensuring that calls are recorded.

BT smartnumbers records calls to mobile and fixed-line numbers – including home-office phones for staff when working from home. The service provides compli-ance for calls and SMS while uniquely supporting team working, recording calls that are delegated to team sup-port staff.

BT smartnumbers stores recordings in the smartnum-bers vault, a highly secure, resilient online storage facility that not only archives and stores the recordings of calls

and SMS messages for the five years required under Mifid II, but also provides a suite of ediscovery and retrieval tools. The solution is provided as a fully managed cloud-based service, so there is no need to install any IT equipment on-site. It’s delivered as a monthly subscription service per user.

TURNING A COMPLIANCE IMPERATIVE TO A BUSINESS ADVANTAGEMore than simply meeting compliance require-ments, BT smartnumbers can become an enabler for greater business performance and organisational agility. For example, BT smartnumbers provides CRM integration to ensure that customer records are automatically updated with fixed and mobile call recordings. The service provides a dual-persona ca-pability which separates business and personal calls made from the same mobile phone, reducing busi-ness costs and providing convenience to staff.

Organisations have traditionally viewed compli-ance as a leveller. Although with the delay to Mifid II, businesses can use the early implementation of customer protection in the short-term to differenti-

ate themselves and in the mid-term as an opportunity to refine their business processes.

FCA advice is that businesses waste no time in pre-paring for Mifid II. Although the 12-month extension has added some padding, many businesses will struggle to implement all of the necessary changes in order to be fully compliant in January 2018.

BT smartnumbers is simple and cost-effective to im-plement. By providing your business and your clients with additional security, it can be used as a strategic dif-ferentiator, while immediately giving you the benefits of improved business agility, increased customer insight and enhanced network resilience. For more information please call us on 020 3162 3030 or visit btsmartnumbers.com. 

F U N D M A N A G E M E N T

H F M W E E K . CO M 17

M I F I D I I 2 0 1 6

THE ORIGINS OF MIFID IMifi d, in force since 2007, created one single market for investment services in fi nancial instruments by creating greater competition and off ering more choice and value to investors. As we all know, the dawn of the 2008 fi nancial crisis changed the fi nancial services landscape forever.

By 2011, the European Commission revisited the provisions of Mifi d I to strengthen them in light of an industry with greater innovation, more complex products, and where changes in both technology and the market were resulting from the 2008 fi nancial markets crisis.

Out of that Mifi d II was born, with an aim of reducing systemic risk by making the markets more resilient and transparent, while strengthening fi nancial stability and increasing protection for investors.

SO WHAT IS MIFID II AND WHAT DOES IT MEAN FOR YOU? Mifi d II aff ects nearly every fi nancial fi rm in the EU, from the giants of fi nancial districts to the small hedge funds across the globe. With only 10% of fi rms ready to tackle Mifi d II reported, a recently announced delay of its implementation may come as welcome news. Th e EU Commission has said that the extension “is to take account of the exceptional technical implementation challenges faced by regulators and market participants.” However, it’s not a signal to sit back and take your foot off the gas. 2018 is not that far away.

So how do you know if you are on track? What are the key aspects your board will need to know and how do you know you’ve identifi ed these, addressed them and have all the procedures, processes and systems to meet your obligations under Mifi d II? With so much talk of the complexities of the directive and the challenges from a technical perspective, we, at AQMetrics, show how the process can be simplifi ed by taking a systematic approach. We’ve identifi ed fi ve key areas where we believe your focus should be in checking your preparations for Mifi d II, while also considering the risk and governance impacts associated with cyber-security.

1. DATA MANAGEMENTCapturing and maintaining data for regulatory requirements remains a signifi cant challenge for aff ected fi rms. Th e increased pre-trade and post-trade transparency requires the publication of data on bid and

off er prices, and volumes of trades at that price, as well as publication of all data on executed trades. Th e primary concern in this area is that publishing this very data may negatively impact both the trades and the related hedges, thus negating the very reason the rules were introduced.

Data capture and maintenance is oft en seen as costly in terms of implementation because of the additional systems and man hours required. One key concern is around how the data will be extracted, calculated and estimated. Participants seem at a loss as to how these will be determined, even though it’s recognised it will have to be done.

2. ALGORITHMIC MODELS AND ANALYTICSUse of algorithmic models to determine investment decisions appears to remain as a signifi cant challenge for aff ected fi rms.

3. BUSINESS OPERATING MODEL AND WORKFLOWTransparency requirements are likely to have the most signifi cant impact on business’ operating models. Both buy-side and sell-side fi rms will have to consider the implications and how they operate in the markets. Under current rules, reporting can be made by third-parties on behalf of investment managers, and in this case, it is the broker who is subject to the reporting obligations.

However, under Mifi d II a narrower exemption ruling applies and where a manager delegates reporting to a broker, it will have to have arrangements in place to transmit the relevant information to the broker. Th is, along with other directives and regulations in place, may lead to more managers assuming responsibility for their own reporting rather than outsourcing to brokers.

4. TRANSPARENCY REPORTINGOperationally, the most signifi cant changes will be transaction reporting, trade transparency and the aff ects these will have around distribution of the product. With the introduction of transparency disclosures and rules, comes the requirement to report on these as quickly as possible up to no longer than one working day aft er the trade. Th is applies to all trades which may be exempt from the pre and post-trading transparency as well as OTC trades, which means increased capacity and requirements to report.

GERALDINE GIBSON, CEO AND FOUNDER OF AQMETRICS, EXAMINES THE BACKGROUND OF MIFID AND OFFERS INSIGHT INTO HOW TO ADEQUATELY PREPARE FOR THE IMPLEMENTATION OF MIFID II

WHAT YOU NEED TO KNOW ABOUT MIFID II

Geraldine Gibson is CEO and founder of AQMetrics. Previously, Geraldine held roles at the Susquehanna International Group and ORACLE, where she advised on risk and compliance services such as risk and regulatory applications, risk analytics, regulatory reporting and compliance monitoring.

F U N D M A N A G E M E N T

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5. RESOURCES AND CAPACITYResources and capacity to manage change along with ‘regulator fatigue’ within businesses further lead to a lagging pace in implementing the changes required. Firms are also under business pressure to free up resources to address regulatory changes and compliance, as well the pressure to reduce costs and resources. Technology can be a very effective way of addressing these challenges. Outsourcing can offer access to technology on a cost-effective and scalable basis, leaving it to the experts to do what they do best. Alternatively, it can replace management control and increase operational risk. It’s important to note that outsourcing regulation, risk analysis and reporting does not relieve a company, or individuals, of their regulatory obligations, but rather offers more capacity for existing resources and budget.

Mifid II adds more regulatory requirements to firms and applies more detailed rules to their operations. It is commented that while the rules implement what is typically seen as good market practice, there are difficulties in applying this regulatory approach to more innovative service-delivery models, which are becoming increasingly common and offer a way of significantly reducing costs.

WHAT ABOUT CYBER-SECURITY?Mifid was brought about to improve competition in financial markets, to make markets more resilient,

increase financial stability and provide greater protection for investors. In providing this, it’s also called for greater transparency of information, data about your clients, your intellectual property, your investors and your funds.

It is the board’s responsibility to ensure a firm has the necessary governance, processes and auditing in place to protect the firm, its investors and its assets. It is no longer the primary concern of the technology department; responsibility and accountability must be registered at the highest level of governance and everyone needs to play their part.

Central Banks across the EU are calling for firms to provide transparent evidence that there are clear policies in place mitigating against cyber-security attacks. Policies should include a risk assessment of the potential exposure, an understanding of the data protection requirements, and business continuity planning in the event of a breach. Cyber-security considerations should extend to market reputation, to the exposure of intellectual property and a liability assessment. All staff must be trained in cyber-security awareness, planning and response procedures. All processes must be audited and the board should have access to real-time management information on the potential vulnerabilities and the firm’s level of preparation.

Over the next number of months, while you’re checking and preparing for Mifid II, remember to consider the risk and governance impacts that are associated with cyber-security too.

MIFID WAS BROUGHT ABOUT TO IMPROVE

COMPETITION IN FINANCIAL MARKETS, TO MAKE

MARKETS MORE RESILIENT, INCREASE FINANCIAL

STABILITY AND PROVIDE GREATER PROTECTION FOR

INVESTORS

”

L E G A L

H F M W E E K . CO M 19

M I F I D I I 2 0 1 6

Financial services have repeatedly had to evolve with regulation over the years. Embrace of new technology and revamped business models has been a demonstrable side-eff ect of the rule-changes even pre-crisis. Equally, some rules have created a number of unintended consequences

in markets, and regulations have been introduced to correct this. Th e newer versions of the regulations oft en have a broad scope. Th e Markets in Financial Instruments Directive II (Mifi d II) is a prime example.

GET THE COMPETITIVE EDGEHaving a robust regulatory compliance framework can give managers a signifi cant competitive advantage that can stand the test of time. Th is is especially important considering the ever-emerging regulations. Firms must be systematic about how they approach the rules. Th ere is typically a four-step approach towards compliance that managers should abide by. Th is includes understanding how the rules will impact their business, which requires a deep understanding of how their fi rm operates;

comprehending the intricacies of the rules; evaluating the impact regulation will have on overall market structure including counterparties and venues and assessing the tools available at their disposal to manage the requirements.

Mifi d II is a massive piece of regulation aff ecting nearly every facet of fi nancial services. Th e rules, which ought to come into action in January 2017, introduce provisions around investor protection, market structure and board level responsibility. Th e rules impose a number of requirements including appropriateness tests for managers of Ucits and alternative investment funds (AIFs) determining the complexity of the products which they are selling. Th ere are prohibitions on inducements and restrictions around managers purchasing research from sell-side brokers through equity commissions. Other obligations include enhanced transparency requirements for investment advice and costs. Mifi d II will also oblige algorithmic traders to disclose information around their trading strategies in what some fear could result in proprietary data leakage.

DR PINAR EMIRDAG, OF COMPLYMATIC, EMPHASISES THE SIGNIFICANCE OF CONSTRUCTING A SOLID REGULATORY COMPLIANCE FRAMEWORK

THE NEED OF A ROBUST REGULATORY COMPLIANCE

FRAMEWORK

Dr Pinar Emirdag is the CEO and partner of Complymatic, a technology and partnerships driven compliance services company. Along with her experience in technology-enabled people businesses, Pinar is a specialist in global regulations, market structures and electronic trading.

L E G A L

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OTFs AND MTFs Mifid II will herald the creation of new trading venues called organised trading facilities (OTFs) for non-equity instruments and multilateral trading facilities (MTFs) as part of its transparency mandate. Other proposals contained in the regulation will initiate restrictions on dark pool trading. Mifid II advocates for open access to clearing facilities and indices as a mechanism by which to improve competition between CCPs and trading venues. These changes will have a significant impact on the market infrastructure operating model. In short, compliance with Mifid II is a huge project for fund managers and it is essential that firms have in place systems to weather the changes.

It is critical for firms to future proof their businesses to deal with further regulatory challenges as well as ensuring compliance with various interconnected regulations simultaneously. Building a framework to meet Mifid II’s stipulations on product governance and complexity will ultimately put managers in good stead for dealing with future iterations of Ucits, for example. Firms need to work towards a solution that is scalable and holistic to meet all of the requirements, especially as their businesses become more complex and global. It is important fund managers outsource to providers who can cater for these diverse albeit intertwined challenges. The winning regulatory compliance frameworks are about processes, people and controls as well as technology. Firms must be cognisant of potential conflicts between various rules. Mifid II transaction reporting could cause data privacy issues for some organisations in certain jurisdictions. Implementing processes to negate this risk and many others should be a priority for managers. Market participants should expect further follow-on rules as regulators seek to attain consistency with all of their requirements.

QUANTITATIVE AND QUALITATIVEMifid II will require fund managers to undertake quantitative and in-depth analysis to determine how the rules will affect their organisations. Any analysis of the rules’ impact needs to assess business strategy and

the implications it will have on internal and external stakeholders. This must include a comprehensive and thorough review on the effect it may have on fund performance. It is absolutely critical managers have a complete understanding of their own businesses and what the changes will bring.

Take the provisions for research. Fund managers need to firstly understand the rules, and how it will impact their research spend, and if necessary scale back on research. This

could be done by analysing which research notes are actually read by portfolio managers and their teams. The budgeting process for research will not be easy given the diversity of asset managers and how they use research. As such, firms need to have a quantitative and qualitative understanding of the impact the research restrictions will have on their organisations.

The process could be made more efficient and seamless by utilising technology. The same systematic approach should be taken by managers who will also need to assess how Mifid II will impact counterparties, venues and clients. Managers will need to scrutinise carefully the market models of fixed income venues, which will now drive pre-trade transparency compliance. The importance of understanding the technology landscape should not be underestimated either. Regulators are continuously updating their processes and many are now supporting industry participants’ use of RegTech as a cost-effective and efficient compliance mechanism.

SINK OR SWIMRegulatory compliance is the cornerstone in the develop-ment of financial services. A failure to adhere to regula-tion or best practices will be a hindrance to any manager looking to raise capital. Investors simply will not allocate to a manager whose regulatory compliance is found want-ing. Having systems and processes that can evolve with the regulation is key. Working with the right partners and technologies can give firms a competitive advantage mov-ing forward to deal with a wide range of regulatory chal-lenges. Once firms have built the architecture to deal with regulation, compliance is broadly straightforward.

REGULATORY COMPLIANCE IS THE CORNERSTONE IN THE

DEVELOPMENT OF FINANCIAL SERVICES. A FAILURE TO ADHERE TO REGULATION OR BEST PRACTICES WILL BE A HINDRANCE TO ANY MANAGER LOOKING TO

RAISE CAPITAL

”

2 2 H F M W E E K . CO M

S E R V I C E D I R E C TO R YM I F I D I I 2 0 1 6

BT smartnumbers, BT smartnumbers // 25-27 Shaftesbury Avenue, London W1D 7EQ // 020 3162 3030 // sales@btsmartnumbers.com

BT smartnumbers provides pioneering smart voice services that help the public and private sector improve organisational agility, resilience and compli-ance. Our team of industry thought-leaders are creating voice services which underpin business transformation, enabling our customers to operate more efficiently, securely and robustly. BT smartnumbers services have been adopted by the leading organisations within the financial services, technology, defence and security sectors. More than 2,000 organisations today take their fixed and mobile voice services over the BT smartnumbers cloud in order to protect revenue and reputation and achieve regulatory compliance.

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AQMetrics, CEO Geraldine Gibson // Dublin: +353 1-629 2607 // London: +44 207-887 2624 // Paris: +33 1 49 91 11 05

AQ Metrics offers investment managers a simple, innovative, and effective way to address regulatory risk and compliance, delivering an ultra-fast and high-quality cloud-based platform to save clients time and money. Their platform integrates pricing, risk and regulatory solutions into a single offering, helping its clients stay compliant while eliminating errors, reducing downtime, avoiding risks and minimising regulatory breaches. AQ Metrics is headquartered just outside of Dublin in Ireland, with offices in London and Paris.

Abide Financial Ltd, T: +44 (0) 20 7148 0971 // sales@abide-financial.com // 2nd Floor, St. Mary le Bow House, 54 Bow Lane, London, EC4M 9DJ

The market leader in global regulatory reporting solutions, Abide Financial manages transaction reporting for financial and non-financial counterparties in UK, Europe and beyond to help market participants meet MiFID, MiFID 2, EMIR, REMIT and international reporting obligations. Since 2011, the firm has delivered proven technology and consultancy solutions to banks, brokerage houses, asset managers, retail trading execution platforms and hedge funds. Website: www.abide-financial.com

Complymatic Limited, 10 Grosvenor Gardens, London, SW1 W0DH // contact@complymatic.com //+44 (0) 203 824 2428 // www.complymatic.com Complymatic is a regulation and compliance specialist firm. Complymatic provides full service compliance consultancy services from regulatory hosting to FCA applications and outsourced compliance. We also assist our clients with their regulatory readiness projects. We are experienced financial services practitioners. Our clients are diverse, from regulated firms to the firms which provide products and services to regulated firms. We believe compliance can be competitive advantage with the right people, processes, and technologies.

netConsult Ltd, Holden House, 57 Rathbone Place, London, W1T 1JU // T: +44 (0)20 7100 3310 // F: +44 (0)870 318 3126 // www.netconsult.co.uk // David Mansfield, COO // T: +44 (0)20 7100 3310 // dmansfield@netconsult.co.uk // Laura Zverko, CMO // T: +44 (0)20 7100 3310 // lzverko@netconsult.co.uk

Established in 2002, netConsult is an award winning provider of managed IT Services to the global alternative investment industry. We aim to provide a high level of technical expertise to our clients combined with a dedication to customer service. Our ethos is based upon designing secure IT platforms which are manageable over the long term. We are a trusted technology provider to a large portfolio of clients ranging from small start ups to large global funds. netConsult provides a bespoke service to its clients and provides a full suite of IT services including cloud services, outsourced IT, BCP, virtual CTO and IT security.

RFA, US: Gair Betts, COO // T: +1 212 867 4600 // 330 Madison Avenue, 19th Floor, New York NY 10017 UK: George Ralph, Managing Director // T: + 44 207 093 5010 // 52 Brook Street, London W1K 5DS

RFA has been the trusted technology partner to our clients for more than twenty five years. Offering a full range of technology solutions with global data center operations, RFA serves the IT needs of businesses including hedge funds, private equity funds, fund of funds, private wealth management and alternative asset management firms. Whether clients require on-site or cloud-based solutions, telephony or data systems, fully-managed IT or project management, RFA has the expertise to meet the industry-specific needs of our clients. RFA is headquartered in New York City with operations in New York, Connecticut, Boston, MA, and London. Website: www.rfa.com

For a more in-depth conversation about what we can do to support you in the preparation and ongoing challenges of EMIR and MiFID II/MiFIR reporting, please contact us: advice@abide-financial.com.

www.abide-financial.com

Abide Financial Ltd is registered in England with company number 7508665Registered office address: St Mary Le Bow House, 54 Bow Lane, London, England, EC4M 9DJ

Single Solution Reporting HubMaintaining complex reporting tools and processes can be a laborious task. It doesn’t have to be. Outsource it to an expert.

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