The long list of topics to be tackled by ESMA in MiFID II Level 2 is laid bare in the EU regulator's latest banking and investment services tender document, with submissions due by the end of this week.
ESMA is seeking help with data gathering and analysis on a number of fronts, not least in order to specify detailed organisational requirements to be imposed on investment firms. With the ESMA guidelines and the FOA guidance already published last year, ESMA may now add even more detailed rules to this thoroughly raked-over area.
Firms should (and do) have clear policies and procedures in place to ensure they meet obligations regarding the maintenance of a fair and orderly market, and a consistent quality of clear governance across the EU is key. But is adding more intrusive red tape for every market participant really the answer when local regulators can provide effective and cost-efficient supervision?
Let's just hope whoever is awarded the tender will help deliver best value.