Potential Member Readiness Activities
MiFID II will introduce several new requirements for members and participants of Trading Venues. In turn these requirements will trigger a number of preparatory activities prior to implementation as well as routines and procedures that will need to be performed continuously or periodically.
The implementation of new MiFID II related system functionalities is expected to occur throughout 2017 and a number of these readiness activities will be associated with required system updates.
In addition, there will be other mandatory member readiness activities required by MiFID II and these activities are also expected to occur in 2017. Below is a preliminary list of such potential activities.
It should be noted that the information herein is not intended to be comprehensive or to provide legal advice on any matter and some of these activities are based on unofficial standards. Consequently the information below is subject to change. Additionally, this list is based on requirements placed on Trading Venues and is not an exhaustive list of requirements placed on Investment Firms.
In time Nasdaq intends to provide detailed information on the implementation of these readiness activities.
|Member Testing Activities||RTS||Asset Class(es) impacted||Frequency|
|Mandatory conformance testing of all order entry protocols (OUCH/FIX on INET, OMnet/FIX on Genium INET)||RTS 7 art 9, RTS 24||All trading venue members, sponsored access participants and ISVs.||Prior to implementation and subsequently, prior to deployment or update to member’s access to TV or of the member’s trading system|
|Coordination and testing support of changes to market data protocols (ITCH/GCF for INET, OMnet/GCF for Genium INET)||N/A||Exchange members, market data vendors and ISVs||Prior to implementation|
|Testing and configuration of transaction reporting for all non-EEA members and members that are not subject to MiFIR||RTS 22||All trading venue members not subject to MiFIR||Prior to implementation|
|Potential testing and upload/registration of pre- or post-trade enriched customer data||RTS 24||All trading venue members||Prior to implementation|
|Testing of commodities position reporting||Commodities participants||Prior to implementation|
|Testing of OTC Trade Reporting (APA)||APA clients||Prior to implementation|
|Member Certification and Data Collection Activities||RTS||Asset Class(es) impacted||Frequency|
|Confirmation of investment firm status||RTS 7, art 7, §3||All trading venue members||Prior to implementation and annually|
|Confirmation from members if they are subject to MiFIR, for determination of transaction reporting obligation. Members that are not subject to MiFIR will need to conduct testing and submit details for transaction reporting to the trading venue.||MiFIR art 26 § 5, RTS 22||All trading venue members||Prior to implementation and annually|
|Due Diligence self-certification of compliance with the rules of the trading venues.||RTS 7, art 7||All trading venue members||Prior to implementation and annually|
|Members self-certification that algorithms have been tested against disorderly trading and means of testing||RTS 7, art 10||All members engaged in algorithmic trading||Prior to implementation and subsequently, prior to deployment or substantial update of a trading algorithm or trading strategy|
|Collection of LEI||RTS 22, 23, 24||All trading venue participants and issuers of listed securities||Prior to implementation and annual verification|
Member Portal Information
The Nasdaq Member Portal will provide customer specific services related to memberships, users, traders, accounts, ports and configuration. The services will be available to members and other customers of Nasdaq.
As MiFID II will require Trading Venues to periodically collect information about Members and other market participants, Nasdaq intends to use a Member Portal to facilitate the automation of the collection of such required MiFID II due diligence information.
The Member Portal will be launched in 2016 and there will be ample time provided in 2017 for all members and market participants to complete required activities related to the member portal prior to the MiFID II implementation deadline. Details will be provided at a later date.
For Additional information, please visit Nasdaq's MiFID II section here or feel free to use these contacts below:
OTC Trade Reporting (APA)
DISCLAIMER:All information contained herein is obtained by Nasdaq from sources believed to be accurate and reliable. However, the Markets in Financial Instruments Directive and Regulation and related level 2 and level 3 texts (“MiFID II/R”) have not yet been fully adopted and/or implemented. Neither Nasdaq Nordic Exchanges nor any of its affiliates or subsidiaries (collectively “Nasdaq”) assumes any responsibility for any errors or omission contained herein. The information herein is not intended to provide legal advice on any matter, nor is it intended to be comprehensive. All information is provided “as is” without warranty of any kind. While the information has been prepared on the basis of the best information available, Nasdaq accepts no liability for decisions taken by any party, based on this information.