MiFID 2 implementation date has finally arrived. We have written an article to remind firms of the key changes and action points.
FCA has also published a series of updates covering:
- transitional arrangements for trading venues, which confirms FCA has agreed a transitional arrangement for ICE Futures Europe and LME, such that the open access requirements of Articles 35 and 36 of MiFIR will not apply to them until 3 July 2020. BoE, as competent authority for UK-based CCPs, has agreed similar arrangements with ICE Clear Europe and LME Clear Limited;
- forms for change of legal status to be used by MiFID and article 3 exemption firms;
- transaction reporting, including guidance on determining which instruments are reportable;
- market data regimes;
- change in control forms for MiFID firms; and
- an updated table of MiFID 2 technical standards.