MiFID 2 and MiFIR appear to offer inconsistent and sometimes contradictory definitions of third-country firms, creating regulatory uncertainty and forcing firms to ask some difficult questions about their business in Europe. As the MiFID “D-Day” gets ever closer, certain aspects of the rules and endless RTSs start to come into sharper focus. Among those is the role, and perhaps plight, of what MiFID calls “third-country firms.” MiFID defines this category… Read More »
Monday, October 19th, 2015 by GEORGE BOLLENBACHER Tucked away in Article 27 of MiFID 2 is a potentially disruptive requirement – the ‘Obligation to execute orders on terms most favorable to the client.’ Unfortunately, what constitutes best execution, and when the rules apply, aren’t clear. As a result, there are 5 tasks investment firms must tackle before MiFID 2 becomes effective at the end of 2016. Tucked away in Article… Read More »
Wednesday, October 7th, 2015 by GEORGE BOLLENBACHER The industrial world has entered a new economic era, and the transition has rendered much of monetary policy largely irrelevant. The Fed has pumped out multiple trillions of dollars since 2008, with no verifiable evidence that the flow had any commensurate impact on economic growth. And now that it is considering tightening monetary policy, we should expect significantly more unrest. While the current… Read More »