The eye of the storm – a MiFID Christmas greeting

As some of you may know, our little company is broadly involved across the Danish financial sector in preparing for the upcoming MiFID regulation. At this point, it seems we are in the middle of the storm, the eye of the hurricane, where everything is eerily quiet.

By Christian Thygesen, Managing Partner | 23rd December 2017

Preparing to go live

It is my impression from across the projects we are involved in, that things are quieting down. Steering groups have understood, asking for new features is way too late, even correcting for known errors is no longer a demand.

Project managers have stopped asking for deadlines, plans and estimates. Right now, the only focus is on stabilizing the features and functionality to go live on 3. January.

Concerns at the moment:

Executive level

At executive level, the concern at the moment seems to be how to tackle the authorities.

Do we tell them up-front about the features that are not ready, or do we wait and see if we can’t get it up and running before anyone finds out? What do regulators really expect, given the persistent lack of clarity (e.g. on cost transparency, in particular on the whole derivatives side), their own lack of contribution (e.g. no golden source to tell the market who is SI in what), and indeed their own change of course past the 11th hour (e.g. on LEI requirements).

Surely, they can’t expect perfect compliance after that.

Anyone who was ever involved in implementing IT changes at this scale will know just how impossible a situation this kind of working conditions create!

But what if these people were never involved in real-life IT implementation? What if ESMA puts pressure on the national supervisors to go ensure compliance on some particular aspect – opaque as the requirements may seem to be from the market participants’ point of view?

Business level

At business level, some are considering back-up plans, partially due to the immediate effect coming from their own systems, partially due to the rumored market effects from non-compliance of the bigger players.

The most dramatic example I have heard is some large UK banks would stop trading on January 3rd as they are unable to report properly!

Project level

At project level – apart from stabilizing the 3/1 go-live – the focus is on internal communication, making sure everyone from the IT nerds to the front line business units know what is hitting them, and maybe in particular clarifying what has been taken out and will thus not be hitting them before some time later in January or Q1.

And trust me, there is absolutely no one who is perfectly ready on 3/1.

For everyone, it is a matter of degree, of getting “something” ready, imperfect as it may be – and on how quickly after 3/1 you believe you will actually be ready.

Holding our breath

For me and most of my colleagues working as business analysts it is now quiet, and not only because of the imminence of Christmas.

We will be at work again before New Year, but mainly to document, consider scenarios – and to hold our breath. January will for sure be challenging as we will try to see through the smoke and dust, work with business on one hand and IT on the other to find the root cause(s) of the errors we will surely see and get them fixed as quickly as possible.

How bad will it be? I really don’t know, but we are soon to find out 😊

A project manager with whom I work closely, had on her last slide the other day: “We believe in the miracle of Christmas”.

I very much agree with her – on more than one level. There is still a lot of work to do to get this pig flying, but worry or panic never helps, so let’s just relax for a few days.

Merry Christmas to all of you out there.

From many perspectives, it will certainly be a most interesting New Year! 



Christian Thygesen, managing partner

Christian Thygesen has been employed in the financial sector since joining the Danish Central Bank in 1992. From 1998 to 2002 he worked for the European Central Bank in Frankfurt, dealing first with financial infrastructure monitoring and then monetary policy in the office of capital markets and financial infrastructure. From 2002 to 2007 he was Head of Projects & Analysis at Roskilde Bank.

Since then he has worked as a consultant in the capital markets area with focus on efficient implementation of regulation and system selection in its many guises.


You can read Christian’s previous posts on the long term effect of MiFID II on the equity market, the bond market, and the derivatives marketon the CMP blog.