Objectives & Project Background
Implemented in January 2018, MiFID II introduced new and more extensive requirements to the existing regulatory framework, and our Financial Conduct Authority (FCA) regulated client needed to comply with the new legislation. Our client, a UK Asset Manager, needed to:
- Review the large volume of guidance papers being issued by the FCA.
- Understand the requirement of the MiFID II provisions relevant to their business.
- Complete and agree a comprehensive impact assessment.
- Based on the assessment, detail and agree an implementation plan to ensure compliance.
- Understand the relevant requirements detailed in MiFID II.
- Understand the impact of the new requirements, identify and agree tasks necessary to ensure compliance, allowing resource requirements and budgets to be planned effectively.
- Formally agree on an implementation plan to ensure compliance by the January 2018 deadline.
- Agree the composition of the MiFID II project board.
- Establish the scope of the MiFID II project.
- Monitor and report project progress to the project board.
- Review all consultation and supplementary guidance papers issued by the FCA.
- Agree a MiFID II framework that divided the Directive into relevant and manageable component parts for the business representatives to assess.
- Manage the production of detailed gap analysis documentation by the business representatives. This analysis included the facilitation of workshops, interviews, and reviewing policy and procedure documentation.
- Produce and sign-off an implementation plan.
- Project brief and Project Initiation Document.
- Project plan.
- A framework, breaking MiFID II into relevant and manageable component parts for the business representatives to analyse.
- Comprehensive MiFID II gap analysis documentation based on the FCA guidance.
- MiFID II implementation plan. The plan contained details of tasks & milestones, resource requirements, timescales, and dependencies and constraints.
The project was a success, meeting its acceptance criteria.