As firms march headlong towards 2018 the detailed implementation of MiFID II is well and truly underway. Even in the equities camp where MiFID II, remember, is an intended adjustment to existing rules, the practicalities of trade and transaction reporting mechanics are evolving.
Whether ESMA ever envisaged such a complex campaign is debatable, but early advocates of splitting MiFID II up into more manageable chunks may not have been far off the mark. Sticking with minimum mandatory change for day one ultimately reduces risk and, with so many moving parts, it makes sense to avoid unnecessary complexity. We could do with borrowing the CFTC's "keep it simple" mantra for US regulation in Europe too as financial firms turn MiFID II theory into practice.