Most of the discussion around MiFID II in an FX context has been pitched in fairly negative terms – yet the industry has much to gain from the clarity the directive will bring to the trading process.
It is understandable that some market participants have viewed the implementation of the new rules with trepidation given that they are required to provide a greater degree of detail around their trade execution.
However, it is also understandable that traders want to see the same level of transparency in FX that they see in equity or fixed income trading.
We have seen that banks are using MiFID II to improve transparency around the FX trading process. By reporting on price construction and displaying cost to the client, the sales desk ‘owns’ this P+L to a greater extent.
This is significant because banks are facing unprecedented pressure on costs. Margins are shrinking and as a result headcount is falling, so it is vitally important for FX sales desks to be able to justify their existence.
One of the most effective means of underlining their importance is to improve efficiency. This can be achieved by getting clients to self-serve but having a management information system to demonstrate value and proactivity in increasing margin/wallet share.
That means client trades can be attributed even if they are done on a self-service basis, increasing the visibility of eFX across the investment banking arm by highlighting the profitability of the sales desk relative to its modest headcount.
Intelligent institutions are overcoming budgetary constraints, using the compliance budgets allocated to MiFID II to re-tool existing systems to the overall benefit of the user.
In conjunction with the Global Code of Conduct, MiFID II has also created a more level playing field within the FX industry. The ability to demonstrate full compliance is vital to maintaining market credibility and will also serve to limit the impact of firms who have used technology to distort the market.
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