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 »
Our News page provides you access to company press releases, CMA professionals in the news, industry recognition and the CMA company brochure. It also provides access to our thought leaders who regularly contribute articles, blogs, quotes and viewpoints on matters affecting the financial industry. In addition, our News tells you when we’re speaking at industry events. From September 9-11, CMA Partner Michael Hartig spoke at the International Securities Association for Institutional Trade Communication (“ISITC”) conference in Washington, DC presenting about “Preparing for New Regulation”. On October 3 in New York, he spoke about FATCA compliance applied to Corporate Actions at the FTF Conference on Corporate Actions Processing. On October 19, CMA Partner Mike Zimits led a panel on, and spoke about Collateral Management & Risk Management of non CCP-cleared trades at the SCI’s 3rd Annual OTC Derivatives Seminar produced by Structured Credit Investor with co-sponsors CME Group, Bingham McCutchen LLP and InterContinental Exchange “ICE”.
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 »
Last week, regulators released their joint report on the Oct. 15, 2014, Treasury Flash Crash. One of the hot topics of discussion has been the prominent role of “PTFs” in the report. So what is a PTF? TABB Group founder and CEO Larry Tabb and George Bollenbacher, partner, Capital Markets Advisors, examine the report, including the definition of a PTF, or a principal trading firm, and how they impact the… Read More »
Thursday, July 23rd, 2015 by GEORGE BOLLENBACHER Much has been written about the impact of regulation on the fixed income and derivatives markets, but market forces also are transforming the space. How are the fixed income and derivatives markets evolving, what is driving the changes, and how can the buy side cope? Ever since the passage of the Dodd-Frank Act and EMIR, and with the looming implementation of MiFIR/MiFID, there… Read More »
Friday, July 10th, 2015 by GEORGE BOLLENBACHER With the impending capital requirements of Basel III in most jurisdictions, banks throughout the world have taken advantage of capital relief trades that allow them to use credit default swaps to alter the risk characteristics of loans on their books. But what impact will this have on the risk profiles of the banks and, perhaps more important, the funds that are selling the… Read More »
Thursday, July 2nd, 2015 by GEORGE BOLLENBACHER Let me begin by saying that I believe the all-important swaps reporting requirement has been badly mishandled by the regulators worldwide, missing a golden opportunity to shed some light on this otherwise opaque market. In the US, one of the nagging problems has been that the SEC hadn’t put out its reporting rules, so there was no required reporting on one of the… Read More »
Thursday, July 2nd, 2015 by GEORGE BOLLENBACHER For any investment firm operating a single‐dealer bond or swap ECN in Europe, MiFID II raises a life‐altering decision: whether to become an organized trading facility or a systematic internalizer. Here are some of the criteria firms must consider in making the OTF‐SI decision. For any investment firm operating a single-dealer bond or swap ECN in Europe, MiFID II raises a life-altering decision:… Read More »
Wednesday, May 13th, 2015 by GEORGE BOLLENBACHER As I have said in past articles, and since every swaps market participant and every swaps market regulator recognizes that transaction reporting has been something of a disaster, we are all waiting to see what the regulators will do about it. Recently, two swaps regulators went in somewhat different directions on this subject. The CFTC First, the CFTC issued two no-action letters (“NALs”)… Read More »
Thursday, April 30th, 2015 by GEORGE BOLLENBACHER The recent publication by the Volcker Alliance of a series of papers on reforming the financial regulatory structure makes interesting reading. You may or may not agree with their conclusions, but I, for one, can’t help but think that there are some important questions about structural reform lurking just under the surface, that were either not asked or were subsumed in these papers.… Read More »