The colossal scale of the MiFID II challenge is self-evident, not only for banks and fund managers but for financial advisers as well. In the lead up to the January 2018 implementation date and following the publishing of the regulatory technical standards, there will inevitably be a mad flurry of activity with firms working all hours to make their systems and processes compliant. However, before then, what should not be forgotten is the low-hanging fruit that compliance officers can pick now.
One of those low hanging fruits is the new requirements around the recording and archiving of calls – both fixed line and mobile. Call recording in financial services is not new and the Financial Conduct Authority (FCA) has already mandated that anyone directly involved in equity trading needs to have their calls recorded.
This requires over 30,000 workers in the City of London alone – at a cost of up to £120 per head, per month – to have their mobile calls recorded. While this is a challenge for some firms, it is certainly not insurmountable.
However, what some financial advisers and wealth managers may not realise is that in less than 22 months’ time, when this European directive comes into force, they too will be required to record all of their calls. MiFID II’s wording is very clear – anyone involved in giving advice that may lead to a trade must not only record their calls, but has to securely archive these conversations for up to five years.