Ensuring MiFiD II operating model compliance

We were called in to assist a wealth management firm with a large discretionary management proposition to conduct a review of their dealing model, where only a subject matter expert could assist.

The challenge

Given our specialist focus in financial services and with a team offering great depth in wealth management, firms often approach us with very specific challenges where only a true specialist can help.

A wealth management firm with a large discretionary management proposition needed a review of their dealing model, where only a subject matter expert could assist. Their main requirement was to understand whether their model was efficient, considering cost, timeliness to market, accuracy of execution, breadth of service and whether it was compliant with MiFID II, the regulatory regime being introduced across Europe.

Our approach

To understand the efficiency of their model, we employed an operating model review with a very narrow scope. Using interviews with the external broker and key members of our client, we built up a picture of the current state which we then compared to market standards. We subsequently reviewed their documentation to ensure that it was equally fit-for-purpose.

We also used the documentation review (for example best execution policies, client agreements and transaction reports) to identify areas where their model would lead to breaches according to the upcoming regulation in the UK.

Our impact

Our client’s model was deployed in a conventional shape, yet an objective lens offered important validation, given the criticality from a client and regulatory perspective.

We delivered recommendations tailored to the client. They understood what was needed to achieve future-compliant policies and procedures. We found elements that would require swift attention in advance of MiFID II. We identified opportunities for quick-wins early on and longer-term improvements that could be made when feasible.

Prioritising recommendations, given the constraints many of our clients face in undertaking change work, is often most impactful. Knowing what is needed is only half the battle: you need a specialist with practical experience.

Note: This case study was first published by Catalyst prior to the Sionic merger

Our experts

Gilly Green

Managing partner