The unbundling of payment for research is a top concern for the industry. There seems to be general acceptance that, one way or another, Europe is set on the soft dollar research market becoming a hard dollar one by January 2017. Despite calls for more clarity and the recent publication of the FCA discussion paper on the regime, opinion remains divided as to how the use of CSAs can evolve to survive as a payment mechanism. There's no denying widespread change is already underway, in roughly the same direction of travel as MiFID II.
This got me thinking about the number of other services, besides research, that are impacted by MiFID II. The sheer scale of its implementation means that plans are already well advanced in most firms in an effort to maximise headway based on the information available. One of the current recognised challenges is keeping up with the waves of regulation affecting every aspect of the financial marketplace, but it's not just the big ticket items for 2017 that need to be managed. As national regulators continue with their own agendas and ESMA marches on with peer reviews amongst National Competent Authorities on supervision - of best execution, for example - firms are having to constantly adapt their 'business as usual' whilst also watching the 2017 horizon.
Nothing endures quite like change.