On Oct. 24, AFME issued guide for wholesale secondary market firms.
AFME and Linklaters issued the MiFIR/MiFID II reforms in the EU and the UK: Implementation Guide for firms operating in wholesale secondary markets.
Follows ESMA Jul. 2024, consult, firms MiFID II order execution policies, see #219595.
Follows UK FCA Jul. 2024, proposals to build up UK wholesale markets, see #220892.
Follows EU CNCL Jun. 2023, agreed negotiating mandate, listing act, see #176061.
MiFIR and MiFID II
In relation to MiFIR, ESMA has issued numerous sets of consultation packages to begin work on the draft technical standards stemming from mandates in Level 1.
UK FCA has been delivering UK Treasury's Wholesale Markets Review through a structured approach and targeted consultations, which is still an ongoing process.
At the same time, the EU and UK have launched initiatives to review essential MiFID investment research rules as per EU Listing Act and UK Investment Research Review.
These respective reviews share the similar aim of bolstering EU and UK capital markets through a revised framework for the investment research ecosystem.
While some reforms have crystallized, many parts of rulebooks are still pending and being revised, so regulatory agenda for secondary capital markets remain very busy.
It is anticipated that the regulatory agenda will remain busy for next 12 months.
AFME's MiFID Implementation Guide provides a holistic yet detailed overview of the statuses and key implementation pain points for AFME's members.
Specifically which are sell-side firms operating in wholesale secondary markets.
Guide covers regulatory developments up until Oct. 1, 2024, and will be reviewed on a regular basis until end of 2025 by AFME accordingly on progress of implementation.
Topics in the guide include market structure, transparency, market data, consolidated tape providers, investment research, and the execution of client orders.
Execution of Client Orders
As an example of changes in client orders execution EU technical standards are being introduced with enhanced requirements in respect of firms' order execution policies.
If finalized as proposed, firms would need to implement more prescriptive processes around their order execution policies, including monitoring and regular reviews.
Draft proposals are due to be finalized and submitted to EU CMSH by Dec. 29, 2024.
AFME believe that client order proposals are likely to apply from Sep. 29, 2025.
Regulators
AFME
Entity Types
B/D; IA; Inv Co
Reference
Rp, PR 10/24/2024; MIFID/MIFIR Dir 2014/65, Reg 600/2014;