MiFID
introduces obligations to prove that your business
is operating with a consistent view of operations.
For example, under the record keeping and reporting
provisions, firms will be responsible for making
available records of financial instrument transactions
to the regulatory authority in a timely manner.
This will include information relating to the
transactions including clients, instruments, quantities,
dates, times etc.
Based on information gained
in the suitability test, firms will be responsible
for evaluating whether a product or service is
appropriate for the client. Best execution obligations
will mean that firms will need to take factors
such as cost, speed, likelihood of execution and
settlement into account when selecting venues
for the best execution. The order handling obligations
will need to ensure that this process is executed
promptly and fairly. Visibility of the combined
order book across the venues as well as access
to internal analytics (e.g. Trade Cost Measurement)
will be critical.