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MiFID: online platforms for distributing funds?

E 'the news appeared in major national newspapers, a study Consob about the possibility of overcoming the crisis in asset management in Italy and "release" the offer to cover through trading platforms of mutual funds themselves. This under MiFID and the new "way of distribution" is underway with the development of 'open architecture "of funds (offered by multi-banking networks).

outlines Consob the "way forward" and issues "technical" to overcome. Here is a small "withdrawn" application of the "Book of Consob Finance" (downloadable from the site http://www.consob.it/ ). We recommend reading the entire document as it is very comprehensive in order to offer an overall improvement in asset management in Italy.

".... The development of a competitive environment, characterized by a range of products and serviziampia and diverse, it is prerequisite to create the market conditions to meet fully the needs of different customers. A first step in this direction could be achieved through the elimination of some imperfections "Rules" that impede the effective development of independent distribution channels, such as telematics platforms. In particular, the completion of the process of dematerialisation of shares of mutual funds, now in the centralization scheme on a voluntary basis, would allow the reduction of transaction costs related to the transfer of shares of funds between different brokers, for the benefit of the contestability of the market distribuzione.Il of work take the form of a discussion paper whose purpose is to bring food for thought about the prospective development of business strategies in the field and collect information relating to the costs and benefits of the quota possibiledematerializzazione of funds. "

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Interpretative Communication of the Consob Regulation /

We received some questions about the recent Interpretative Communication of the Rules of Consob.Ci seems interesting to note the problems relating to the" passage "from a SSO inherent in trading on unlisted shares on regulated markets (such as shares of a banking institution that is not listed on regulated markets) to a task "MiFID compliance.

Consob says: "........
In general, it is noted that the provisions of Consob Regulation 16191 on markets and in the text of the communication in question is what specifically required by MiFID and the EU Regulation 1287/2006. As noted, the definition of systematic internalisation does not contain references to the object (financial instrument) activities carried out by authorized person. Identifying elements of the activity of systematic internalisation therefore apply to both the world of actions and activities concerning securities other than shares .
That said, we recognize the operational difficulties - due to the broad scope of requirements - involved in assessing the request to qualified parties for the traceability of its activity to that of systematic internalisation. Notes, However, remember that the activity of systematic internalisation to be identified as such requires the simultaneous presence of conditions relating to: i) the commercial role; ii) the existence and operation on the basis of non-discretionary rules and procedures, iii) the course by staff or by automated technical system for this activity, regardless of whether the staff or the system are used exclusively for that purpose; iv) accessibility to clients on a regular and continuous ...... ..
..... Observation showed Assiom
ABI and the opportunity to limit the identification of the factor di internalizzazione sistematica legato al “ruolo commerciale rilevante”, anche in relazione all’operatività per conto proprio dell’intermediario condotta nei confronti della propria clientela su strumenti finanziari non azionari di propria emissione. A tale riguardo, viene evidenziato come l’attività di mercato secondario di riacquisto di emissioni obbligazionarie proprie non debba ricadere nelle attività aventi un ruolo commerciale rilevante per evitare che gli intermediari – nel timore di doversi dichiarare internalizzatore sistematico – abbandoni tale tipo di attività di servizio nei confronti della clientela che ha acquistato emissioni cosiddette
“branded”. Viene richiesto, therefore, to be maintained a system of post-trade transparency in line with that set out in CONSOB 14 035 of 17 April.

It seems clear that there is no distinction made between actions and not understanding that post-trade transparency is maintained in line with Consob n.14035 (SSO). In essence, after March 31 each SSO (which will cease to exist "as a definition of alternative trading system") shall have the right to continue its operations or in the guise of a systematic internaliser (with Consob communication no later than March 31) on their own or as normal (with transparency equal to repeat what happened before -but in this case MiFID also talks about the conflict of interest, for which there is an optimal choice NOT-) or as part of an MTF.

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MiFID MiFID: News from Forex in Bari on 19-20 January. Article 34 of


Forex

The conference of 19 and 20 January, outside of considerations of the market (subprime crisis, stock exchanges, asset management crisis) was an opportunity to verify the situation of banks and financial institutions the Italian state of the art post MiFID. Of particular importance to the opinion of the director general of ABI Giuseppe Zadra explained that the point of view of banks. According to authoritative opinion, "the Italian system" is characterized by the presence of a large retail and General score less exposure to the asset management than European countries. This raises the question on education at the counter (and related contracts to be submitted to the same score). Not easy to solve but the "question" of best execution for a product without a plurality of execution venues, but we think (we in the drafting of www.mifidnews.blogspot.com) that this is a problem of all the members of the MiFID not only at national level.

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d.16191 (markets)

Sometimes our job is to report doubts regulation (or interpretation). Resume Article 34 of d.16191:

Article 34 (post-trade transparency requirements for qualified entities)
1. Authorised persons for any transaction entered into, make public the following information:
a) day and hour of trading;
b) identification of the financial instrument
c) price and quantity of the operation ended.
2. The obligations under paragraph 1 shall apply to actions:
a) concluded outside a regulated market, an MTF or systematic internaliser on financial instruments admitted to trading on Italian regulated markets other than shares ;
b) with an amount less than or equal to 500,000 € .
3. For transactions that exceed the threshold specified in paragraph 2, letter b), authorized persons shall make public the information about at least a day and hour of trading, the financial instrument identifier and the price and an indication that it is operation above the threshold set out in paragraph 2, letter b).
4. The information referred to in paragraph 1 shall be published with reference to each transaction by the end of the business day following that on which the transaction was concluded. Are made public on reasonable commercial terms and in such a way as to be easily accessible.
5. Apply paragraph 5 of Article 29 and paragraphs 4, 5 and 6 of Article 30.
6. The provisions of this Article shall not apply to the wholesale trading of government securities .

The question that arises is: What is wholesale trading of government bonds ?

as a market Mts as it is a regulated market (see list of regulated markets http://www.cesr.eu/ ). The clarification of "the wholesale trading of government securities" and "strengthening" of the concept that these rules should not apply to transactions made on Mts as a regulated market to include all effects (see website http://www.cesr.eu/ ) . Also, if a government bond (for example) is purchased for an amount greater than € 500,000 on a platform and OTC (eg a broker on Bloomberg), according to subparagraph b, shall not be made to the alert.

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AIM (Alternative Investment Market)

The merger between the Italian Stock Exchange and London Stock Exchange has opened up new vistas in Europe. A rumor sweeping the Italian financial community and that is the possibility to be "imported" the "market model" for the entry of an AIM (Alternative Investment Market) in Italy. The news seems positive as the remarkable success of this market dedicated to small and medium-sized enterprises in London, but there are two fundamental problems: the first is

-source "nationalistic" since the beginning of the MiFID initiative already exists on the Mac (market alternative capital) just built on the initiative of the Italian Stock Exchange (why "import" a direct competitor (or a clone)?

-the second is an even greater motivation: nell'Aim are the same broker that "ensure "in a sort of self" and take charge of compliance with the minimum standards for listing the companies. In Italy, the competent authority to give the green light at and consent of the 'aim Italian "wants to be sure that they comply with all regulations and ethical principles that ensure the protection of investors.

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MTF: AKTIETORGET

AKTIETORGET

AktieTorget is an Electronic Market Place (SAKESS) where actions are treated with high growth potential. The system is affiliated with the Stock Exchange of Norex Stoccolma.E 'a system characterized by high technology, combined with low costs and ease of timing in the event of listing, but is regulated and supervised by the Swedish Financial Authority (and of course the "rules" within the EU MiFID). AktieTorget has become, since November 1, 2007, MTF (multilateraltrading facilities).

Multilateral trading facilities

Mic code XSAT

Website: http://www.aktietorget.se/

country code SE Authority: Finansinspektionen

Tools negotiations: 100 shares

Trading hours: 9.20 am - 5.20 pm

Example ordinary share

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software company specializing in electronic

Volume

day (n.azioni treated): 27,500

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MiFID: eliminated the tax on contracts

using engineering terminology, the Government approved the "photo finish" (dated December 28, 2007) the abolition of tax on contracts as required by MiFID, as has already been largely developed on this blog the presence of such a charge to override the "spirit" of the MiFID in fact created a different treatment of contracts on the same title on regulated markets (free of charge) and treated in other markets (internalization / mtf) was included where such taxation. The "lucky" if we want to call it that, is that at present there are very few locations where (see www.cesr.com - internalized and mtf list) are listed alternately Italian shares (listed on the Italian Stock Exchange) and the case is therefore virtually non-existent. It remains the view that in two months (starting November 1 of MiFID ) has nevertheless experienced a paradoxical situation in terms of law and not to "blame" or investors, or speculators or banks and a modest reduction in tax revenue than in the past (about 2.7 million euro).