From the LME Regulation Team
With the final quarter of 2017 almost at hand, the MiFID II implementation date of 3 January 2018 is fast approaching. The first MiFID II related proposals were published in 2011, meaning the evolution of this legislation has been long and fairly protracted - particularly in view of the 12-month delay pushing the implementation date from 2017 to 2018. Whilst at times it may have felt like implementation would never arrive, that day is now just around the corner and if you aren’t already eating, drinking and dreaming MiFID II, then rest assured you will be very soon.
The vision of imposing regulatory alignment on the full scope of the European Capital Markets is a brave and highly ambitious one. However, the breadth of MiFID II’s legislative ambit, combined with the variety of the markets to which it applies, the minutiae of its obligations and the complexity of implementational change it mandates, means that the task of making that concept a reality has proved Herculean.
We are acutely aware of the challenges that MiFID II implementation and compliance introduces to our market and how these will affect our users. The LME and LME Clear have worked consistently on understanding this legislation since the embryonic days of MiFID II. Legal text has been scrutinised, business models reimagined and regulators quizzed at length. As our implementation programme reaches its final stages, we are engaging closely with our members and broader market participants to provide information and resources designed to help their understanding of MiFID II, so that their implementation projects can be completed accurately and on time.
To this end, we’ve refreshed the MiFID section on our website, which provides detailed summaries of the application of MiFID II to all users of the market – whether you are a member or a client and irrespective of whether you are based inside or out of the UK/EU. The site also provides information for non-European firms in respect of the impending legislation and how it might affect you when operating within the LME ecosystem. In addition, in order to assist with firms’ implementation programmes, the site also offers details of our testing environment, specifications and timelines of changes to key LME systems that will be running until 3 January, as well as detailed information on key MiFID and MiFIR texts.
Whilst the ultimate success of the project at a pan-European Level will remain unclear for a number of years, we are confident in the work that the LME has done in order to achieve MiFID II compliance. We have appreciated the high level of engagement from our members and from the wider metals community throughout the process and this has allowed us to better gauge the impact of this regime on the wider metals market.
As the final weeks leading to 3 January tick by, we will continue to work collaboratively with all members of the market to ensure a smooth, compliant and timely implementation of the MiFID II requirements.
If you have any queries in relation to the impact of MiFID II on your LME trading activities then please email our regulation team or your usual LME contact.