Amidst the on-going rumblings about delays to MiFID II, and the budget and planning uncertainty this has created, it's good to see that market participants continue to press on with implementation. MiFID II includes many new obligations for venues and, for investment firms, knowing what the exchanges will do fills a significant piece of the puzzle in their overall plan. Despite the lack of finalised detail, the groundwork that has been collaboratively covered by the industry over the last few years means that there is a pretty good consensus on how some of the new regulations can work in practice. Promisingly, we are now starting to see some real traction as the first exchanges start to set out their stalls for 2016. Hats off to BATS and we look forward to seeing more of the same.
The most effective use of any extra time that a delay may afford us is to keep pushing ahead. Given the lengthy process necessary to amend the January 2017 implementation date for MiFID II, and the added complexity around moving the transposition date, more certainty could still be some weeks or even months away. The best way to approach MiFID II is to keep your eyes on the prize and carry on.