On 2 November, AMF proposed rules for final implementation of MiFID II.
- he proposals amend procedures for the approval of investment service providers.
- Amendments concern Book III and Book V of AMF’s General Regulation (RGAMF).
- Rules relate to authorization procedure for management, MTFs and position limits.
- But also introduce provisions for the managers of organized trading facilities, data.
- AMF is also proposing deleting sections which have now been superseded by MiFIR.
- Investment advisers to be subject to equivalent conduct rules as investment firms.
- Comments are due before 1 December 2017.
On 2 November, MFSA issued circular on transaction reporting for MiFID II.
- On 26 October, MFSA seminar on MiFID II provided overview of legislative requirements.
- During seminar industry raised queries relating to transaction reporting requirement.
- Circular provides further analysis on some queries which were raised during seminar.
- Guidance on content, timeline, collective investment schemes, legal entity identifiers.
- MFSA will replicate TRS fields in Transaction Reporting Exchange Mechanism (TREM).
- Three-phased approach to adopt TREM: on registration; connectivity test; validation.
- Phase 1 – Registration, all entities which will submit, to file form to get TREM access.
- Phase 2 – entities registered for TREM, able to test connectivity with MFSA mid-Nov.
- Phase 3 – MFSA will be ready to receive reports for validation testing mid-December.
- Submit compressed files, of XML file on MIFIR XSD schema will be parsed, validated.
Funds and LEI
- MiFIR does not apply to managers of Collective Investment Schemes, as per details.
- Cited MFSA 9 August 2016, circular reminding of need for legal entity identifier (LEI’).
- MiFID II enters into force on 3 January 2018.