Communications - including voice, social media, email, and text messaging - play a central role in complying with MiFID II requirements. Beginning January 3, 2018, firms will be required to:
Alcatraz preserves the conversational context of 80+ communications channels natively and with partner connectors to address Article 16 Record Keeping requirements
Vantage enables enforcement of policy controls across voice and all eCommunication channels, including Article 16 requirements to retain communications that lead to a transaction for 5-7 years
Alcatraz provides a scalable content store with lightning fast ingestion, search, and export to meet Article 16 Storage and Supervisory requirements
Actiance provides an open, extensible platform with full APIs to deliver communications for aggregation with surveillance and trade reconstruction applications to meet Article 16, 24, 25, and 31 requirements
Enable the real-time capture of voice communications delivered on UC platforms, financial services trading systems, mobile devices, and collaborative platforms - natively and with best-of-breed partners
All communications are unified to simplify search and review conversations on voice, IM, email and social channels. Preservation of conversational context enables fast, effective response to MiFID II regulatory inquiries
Robust supervisory review capabilities enable firms to ensure that managers, employees, and agents comply with the MiFID II directive. Firms review conversational context of communications occurring within and across 80+ communications networks. while robust APIs seamlessly deliver content to surveillance applications
Actiance’s unified content store is complemented with a complete set of APIs to power trade reconstruction and behavioral analysis tools. This allows firms to marry communication activities with financial transactions for a comprehensive MiFID II surveillance platform to simplify the process of supplying regulators with all the communications associated with specific trade events.
Actiance allows financial services firms to meet record keeping, retention, storage, and supervisory requirements of MiFID II with an integrated platform that captures and preserves 80+ communications channels, which can then be harnessed to understand investor communications leading to trade events. Vantage and Socialite provide forensically-sound compliant capture and Active Compliance controls, while Alcatraz enables the immutable storage and supervisory review of conversations in context. Open APIs enable communications to be aggregated with trade data from full reconciliation of trade events to meet MiFID II / MiFIR requirements.
“We are likely to see a historic shift on how assets are being managed and invested, as our distribution partners are changing both their product preferences and their use of technology to adapt to these rule changes. ”Larry Fink, Chief Executive of BlackRock (Financial Times 1/26/2017)
Originally implemented in 2004, the Markets in Financial Instruments Directive (MiFID) was original designed to increase competition and investor protection in financial investment products. While MiFID served to provide harmonization of financial market operations across member EU states, it failed to deliver the investor protections that became exposed during the 2007 financial crisis. The limitations of MiFID included 1) the creation of new derivative financial products, 2) the participation of a broader set of investors that are active in the market, and 3) new communications tools used to market and sell financial products.
MiFID II and its accompanying regulation outlined in the Markets in Financial Regulation (MiFIR), attempt to create greater market transparency, a ‘level playing field’ for investors large and small, and a broader set of communications that lead to a trade event. MiFID II is very comprehensive with over 90 articles in total addressing market operations, investor protection, record keeping, supervision, information storage, as well as other reporting obligations. MiFID II regulations require that financial services firms capture and preserve all communication forms, including email, voice, records of face-to-face communications, social media, etc. that directly relate and lead up to a financial transaction. MiFID II regulations require that the information be stored immutably for 5 to 7 years in a format that allows for the fast retrieval and search of those communications. Once those communications have been stored, firms need to associate them to trade events as part of a reconstruction process, in order to ensure that firms have met all applicable MiFID II regulations.
MiFID and MiFID II requirements create a number of technology, process, and infrastructure challenges for financial services firms. MiFID requirements are aimed at providing better investor protection, ensuring that markets are operating efficiently and transparently, and reflect the unique challenges created by new financial products and new communications tools in use in the marketing and sale of financial products. MiFID requirements include the need to capture all communications that are associated with a trade event, which can include traditional channels including email, but now must also including voice recording, and a variety of financial networks and messaging apps including Symphony, IceChat, Thompson Reuters, Bloomberg, Slack, Skype for Business, Cisco Jabber, and others. MiFID requirements for capture of this breadth of communications sources will cause firms to re-evaluate their ability to preserve those content sources via custom built approaches or through native access to each communication network.
MiFID requirements include the need to capture all communications that are associated with a trade event, which can include traditional channels including email, but now must also including voice recording, and a variety of financial networks and messaging apps including Symphony, IceChat, Thompson Reuters, Bloomberg, Slack, Skype for Business, Cisco Jabber, and others. MiFID requirements for capture of this breadth of communications sources will cause firms to re-evaluate their ability to preserve those content sources via custom built approaches or through native access to each communication network. MiFID requirements for the retention and storage of these sources entails the assignment of retention policies to each network, the immutable storage of that content, as well as the use of a storage technology that enables the fast search and retrieval of that content. Supervision is also a key MiFID requirement, to ensure that firms are conducting review against all communications sources to ensure adherence to MiFID II and MiFIR mandates. Finally, supervised communications will need to be associated with a trade event to perform trade reconstruction to meet MiFID requirements.
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