Intended to promote practical convergence and common supervisory approaches and practices, like EMIR and MAR before them, the MiFID II Q&A is fast becoming a favourite on my browser. In its recent Q&A on transparency topics, for example, ESMA has clarified for those firms wondering if, when and how to become a systematic internaliser (SI) that they will have until September 2018 to work it out and comply.
Waiting until after ESMA has published the first set of trading data in August before completing the assessment for SI status sounds logical, but it doesn't allow much time to put the plumbing in place. So in practical terms firms are already estimating their status and building out their systems ready to opt-in from January 2018 or switch on by September. Quite what the relative impact will be for early versus late joiners is a new unknown.
With the list of questions on the practicalities of MiFID II implementation growing by the day ESMA's question and answer mechanism is set to become a much-utilised tool.