I just got this chart from the FT via Chris Giles:
The chart clearly shows that from the Spring of 2009, algo trading rocketed whilst human trading plummeted.
I just got this chart from the FT via Chris Giles:
The chart clearly shows that from the Spring of 2009, algo trading rocketed whilst human trading plummeted.
We had our first meeting of the Financial Services Club Nordic Region last week at the British Embassy in Stockholm.
Attended by around 70 senior figures from the financial markets across the region, we discussed the changes and implications of change in European investment markets, with a focus upon the processes involved in pre- and post- trade areas.
The panel consisted of three luminaries who could relate to the topic in depth:
As mentioned yesterday, we finished the debate at the CAS-WG Plenary with a panel discussion about the future for the City and the UK financial system in light of European regulatory change.
The panel consisted of (from left to right):
It was a fascinating 45 minute discussion of the negative position the UK sits in today, from a regulatory perspective in Europe. The Banking Union, Transaction Tax, Bonus Cap and more, has all hit London hard so, unsurprisingly, this was a pretty negative debate about where the regulators have got to in Brussels.
Here is a short synopsis of what was said ...
We had our fifth plenary meeting of the Clearing & Settlement Working Group (CAS-WG) in March.
The meeting covered all the latest issues, news and views, and was kicked off by Greg Caldwell, Chair of the Regulations Subject Group, who outlined the complexity of European and Global Regulations through this slide outlining the Rubik’s Cube of Regulations.
In February, the European Parliament published the technical standards for the European Markets Infrastructure Regulation (EMIR). The standards were published in the Official Journal of the European Union on 23 February 2013 and will enter into force on 15 March 2013.
To find out what this means, why not join us on Wednesday 14th March when we have our fifth plenary meeting of the Clearing & Settlement Working Group (CAS-WG) at the BT Auditorium, 81 Newgate Street, LONDON, EC1A 7AJ.
Good evening ladies and gentlemen.
I wasn’t sure how to start this evening, and decided to begin with the collective noun for a group of CRO’s. You are collectively known as a murder.
Now I hope you won’t murder me for telling you that as a murder of CRO’s you are a collective failure.
Oh dear, that’s not a good start, is it?
We had the final 2012 plenary meeting of the Financial Services Club Clearing & Settlement Working Group (CAS-WG) yesterday.
Well attended by industry luminaries, the debate was all about the usual stuff: regulations, standards, risk, issues, frustrations and opportunities.
What was particularly interesting for me is that we now have three subject groups working in unison to solve many of the issues and frustrations in order to identify and leverage the opportunities.
A wave of regulatory change
Further to the launch of the Clearing and Settlement Working Group (CAS-WG) in the spring (read more here), the Subject Groups have been meeting regularly and have progressed towards building a regulatory risk model to test the impact of new regulations on clearing and settlement infrastructures.
This will be discussed in depth at our next plenary meeting which will take place on Tuesday 11th December at the offices of Kemp Little, Cheapside House, 138 Cheapside, City of London, EC2V 6BJ.
I bet you thought I was talking about Europe's sovereign debt issue but no, I'm talking about the average trade size for equities trading across Europe having just received some fascinating data from the Federation of European Securities Exchanges (FESE).
The data shows a considerable change in the European equities markets over the past four years.
I was going to write one final piece about Japan, on a more serious note, as the SIBOS week really brought home to me the fact that there is a two speed financial world being regulated under one regulatory agenda.
There are the growth markets of Asia, Africa and Latin America, who want regulation to encourage banks to support growth; and there are the recession markets of Europe and America, who want regulation to manage austerity and budget cuts and avoid unacceptable risks within the financial system.
The result is that you have markets that do not work at all.
Banks and hedge funds will purely morph to where the money is – Asia and its allies – and get out of the markets where there is no money, such as Contintental Euorpe.
As I say, was about to write this piece when I read the Wall Street Journal’s headline opinion piece, which pretty much said what I was going to write.
Therefore, if you missed it, here’s the real impact of Dodd-Frank (and the European Market Infrastructures Regulation, EMIR):
We had a great meeting at the Financial Services Club Clearing & Settlement Working Group (CAS-WG) plenary this month.
The CAS-WG is rocking and rolling forward, with four subject groups meeting regularly between the plenary meetings.
The four subject groups focus upon the challenges of clearing and settlement to deal with risk, regulations, standards and market infrastructure operations. Each group has nominated chairpersons:
and are moving forward with focus.
At the July plenary each Chair gave an update of their group’s progress, along with two panel discussions in between.
The first panel discussion debated the merits of the European Market Infrastructure Regulation (EMIR) which is now in consultation with the European Securities and Markets Authority (ESMA) through 5th August, before ratification by the European Parliament at the end of September for implementation in 2013.
The second panel picked up on the ISO17442 standards for Legal Entity Identifiers (LEI). These are agreed for rollout from March 2013, and should make it far easier to track and monitor OTC Derivatives and other financial instruments as they move between different clearing systems.
This area was discussed in depth by:
So I’ll start by writing up a little bit on this debate.
By way of background, Legal Entity Identification (LEI) is a new ISO standard (ISO17442) which will apply to all Financial Contracts from 2013, according to an agreement made by the G20 earlier this year.
This means there will be a single, universal standard for identifying all parties involved in a financial contract, and will make it far easier therefore to see counterparty positions should another crisis occur such as the Lehman’s crash.
The standard has been established by the U.S. Treasury's Office of Financial Research following proposals by the Depository Trust & Clearing Corporation (DTCC) and SWIFT.
SWIFT will act as the registration authority, acting on behalf of the International Organisation for Standardisation (ISO) to assign the ISO 17442 LEI standard. The DTCC will act as the facilities manager which will receive, review and publish entity information.
The development of a single global standard for LEIs is a key element in the broader effort to understand and monitor systemic risk across banks and capital markets.
Furthermore, LEIs will allow Trade Repositories to keep a single record of a financial instrument, which will make it far easier to sort out a liquidity or counterparty collapse.
For a comprehensive background of the development of this standard, you can checkout this document: download LEI timeline of events.
Interestingly, in Virginie’s update on standards, she had picked up this chart from the Financial Stability Board’s list of recognised and approved trade repositories:
It shows the DTCC’s strength, which some are calling a monopoly, and a lot of discussion took place about concentration risk when so much dependency is placed upon one CCP.
On the other hand, some argued that concentration of monitoring is a good thing, as the more centralised a single record of risk, the easier it is to manage.
The general discussion however was the feasibility of implementing a single global standard for LEI’s.
James was adamant that this has been agreed and is being rolled out, no matter what other standards are mooted.
In the earlier panel:
discussed EMIR, the European Market Infrastructure Regulation.
EMIR has three objectives.
First, to reduce counterparty risks by:
Second, to create safe and resilient central counterparty systems (CCPs) by developing a comprehensive set of organisational, conduct of business and prudential requirements for CCPs.
Third, to increase transparency by:
The text of EMIR was issued on 25th June 2012 for consultation, and the consultation will close on 5th August. At this point it moves into Parliamentary submission for full EU endorsement on 30th September 2012.
That’s a rapid cycle regulation and led to a lengthy dialogue around the effectiveness of the rapid cycle consultation process taking process around EMIR, and whether with Basel III, Dodd-Frank, the LIBOR crisis and other issues, the regulatory framework was being too rushed and fragmented or whether it could actually work.
In particularly the whole notion of transparency was questioned as to whether it was a good or bad thing. Peter Randall was particularly dismissive, describing it as being like an airline security system. The idea of a secure airline is one where all passengers fly naked. You know you’re safe as everyone can see what everyone else is carrying with full transparency. However, there wouldn’t be many passengers.
That is the fear for the impact of EMIR: that it creates transparency but all trading and liquidity disappears.
Robin Poynder made the position clear when he said that you may not like the regulatory framework, but the regulators are pushing through their changes whether the markets like them or not, and are even willing to see markets collapse if that’s what it takes to make them effective.
In other words, whether liquidity is there or not after the regulatory process, they really don’t care as long as the markets are safe.
Kathleen responded by saying that this is more likely to result in a flight from the markets, where these regulations force full transparency and movements to other geographies. What that means in reality is that you see liquidity disappear in the markets where they are needed – Europe and America – leaving only higher risks for the pension funds and corporates trying to manage their collateral.
From the Subject Group updates, the main highlights were their progress in creating future agendas.
The Risk Subject Group was discussed by Shaun Cooke, and has four focus areas:
The aim is to develop these areas into working papers and recommended best practices to share across the Subject Groups and other interested parties.
The Regulations Subject Group update came from nominated Chair Rory Webster, a Director with trade repository CapitalTrack Ltd.
The Subject Group is working in two key areas today:
In particular, the group has initially focused upon EMIR and how it affects non-financial counterparties: will they be caught up or caught out by the regulation?
Bearing in mind the short-term focus for input to the consultation process by 5th August, the Subject Group asked for all input to be sent to the CAS-WG Chair by 2nd August 2012 to ensure our views are represented effectively to ESMA.
The group has also drawn up a matrix of regulations and how they impact different market functions, which is available from group co-chair Greg Caldwell of aSource Global Ltd if required.
The Standards Subject Group has focused upon trade repositories and the DTCC, and their slides – compiled by Standards Subject Group Chair Virginie O’Shea, Lead Analyst with Aite Group – can be seen below (from Slide 15):
The main activities of this group are to:
With the aim to:
The focus areas of the group include:
And the Group will identify:
In their on-going meetings.
Last, but not least, the Market Infrastructure Subject Group chaired by Kathleen Tyson-Quah of Granularity Ltd, are looking at the models for market complexity and are creating their own map of these structures to avoid any surprises.
The model the Group has developed will track the harmonisation of regulations and standard, and identify any overlaps or conflicts these create in the market infrastructures.
This is something I have advocated for a while now: we need a clear map of how the changes to system, structures, standards and regulations relate to each other.
Price formation is also on the group’s agenda, as the current LIBOR crisis will expand how pricing is set. Historically, prices have been set using mark-to-market reference rates, but self-certifying reference rates for derivatives pricing will now be called into question and change demanded. What will this mean for markets?
The group also recognises that there are 20 new CCPs being built today, with six in London alone. Does this mean too much concentration risk? It certainly means that there are changes to the way CCPs are capitalised.
Finally, the group is reviewing the impact of the new rules for clearing and settlement announced in April, when CPSS-IOSCO released three reports:
The new principles are designed to ensure that the infrastructure supporting global financial markets is robust and well placed to withstand financial shocks, with the new rules applicable to all systemically important payment systems, central securities depositories, securities settlement systems, central counterparties and trade repositories (collectively “financial market infrastructures” or FMIs).
These FMIs collectively clear, settle and record transactions in financial markets.
As mentioned, the Group’s deliverable will be a model that maps out all such changes, and makes clear the implications.
So there you have it.
Four Subject Groups and two Plenary Panels.
The Subject Groups will continue to meet through the summer and the next plenary meeting will be in September.
If you’re interested in joining in, just let me know.
Following on from the recent CAS-WG plenary session we are pleased to advise of the following dates, venues and times for the next Subject Group meetings.
Regulation: Monday 18th June, 4.30 - 5.30pm at SNR Denton, One Fleet Place,
EC4M 7RA Register here
Standards: Tuesday 19th June, 4.15 - 6pm at BT, Faraday Buildings, 1 Knightrider Street, EC4V 5BT Register here
Risk: Wednesday 20th June, 3 - 5pm at Grant Thornton, 30 Finsbury Square,
EC2P 1AG Register here
Market Infrastructures: Thursday 21st June, 4 - 5pm at The London Stock Exchange, 10 Paternoster Square, EC4M 7LS Register here
The meetings will confirm Chairs for these Subject Groups and would like to remind you that these sessions are open to all and free to attend.
You are also reminded that the next plenary meeting will take place on 18th July at BT's Head Office in Newgate Street. Register here
Yesterday marked another milestone in the progress of the Clearing & Settlement Working Group (CAS-WG), with our second plenary meeting.
This time it was held at the London Stock Exchange ...
... and discussed the progress of the four Subject Groups that were created after our first meeting at the beginning of March.
Since then, the four groups have met twice and created a rough agenda of their focal points.
It should be noted that these groups are still fledgling however, and until our next plenary on 18th July are open to influence. For example, two are still without confirmed Chairs and the other two Chairpersons will only be confirmed at the next meetings to be held in mid-June (if you want to Chair or Co-Chair any of these groups, then you need to attend or put your name forward for these meetings).
The four groups are looking at the impact of change in clearing and settlement infrastructures and cover:
The aim of the four groups is to take the mass of regulatory change – Dodd-Frank, FATCA, EMIR, MiFID II, Basel III and more – and work out:
with the intent of arriving at conclusions which can be communicated to all parties.
The Subject Groups are open for anyone to attend, and are intended to generate a 360o view of the changes required for Clearing & Settlement over the coming years.
This is why we fully expect CSDs, CCPs, buy-side, sell-side, solutions providers, fund managers, corporates and more to get on board with the CAS-WG over time, many of whom were represented in the room yesterday.
The meeting covered the four working groups, who outlined the initial themes explored.
The Risk Subject Group is focused upon:
The Group has nominated Paul Young, Associate Director for Business Risk Services at Grant Thornton as its Chair, and the next meeting of the Risk Subject Group will be on 20th June 2012.
The Regulation Subject Group is focused upon:
The Group has Kiri Self of the Realisation Group as Acting Chair, and is open to nomination for this position. The Group’s next meeting will be on 18th June 2012.
The Standards Subject Group is focused upon:
The Group has Darren Pearson of the Realisation Group as Acting Chair and is open for nomination for this position. The Group has its next meeting on 19th June 2012.
Finally, the Market Infrastructure Subject Group is focused upon:
The Group has nominated Kathleen Tyson-Quah of Granularity Ltd as its Chair, and has its next meeting on 21st June 2012.
After the outline of the discussions of each Subject Group, the plenary also had several panel discussions about the emerging themes under discussion and debate.
The first panel comprised:
What came out of this for me was a lot of discussion about:
The outcome overall of this first panel was a clear view that markets have to wake up to the fact that if they cannot quantify and measure risk, then they should stop trading those products that create such risks.
That would be an awesome change of attitude.
The second panel comprised:
This panel continued the dialogue with specific commentary around:
The end result of these discussions included further questions from the floor, including a few challenging ones:
All in all, a very positive start and lively future for the CAS-WG.
If you want to join in, attendance is free. The dates of future meetings are:
Oh, and there is an informal lunch on 10th July at Canary Wharf about Central Bank Systems for those interested too.
This week saw the inaugural meeting of the Clearing & Settlement Working Group (CAS-WG), which was well attended by over 100 industry figures from all parts of the investment markets and hosted at BT’s City Head Office in St Paul’s (BT are the first sponsor of the CAS-WG).
The CAS-WG has been initiated by the Financial Services Club to provide an opportunity for open discussion and debate amongst senior market practitioners and service providers on issues affecting Clearing and Settlement, and is created in partnership with the Realization Group who facilitate our Subject Group meetings.
The aim is to provide specific input to the regulatory bodies – including the FSA, its successor bodies the PRA and CBA, and Michel Barnier’s team in the European Commission – on the technology implications of regulations in draft and final form that affect Clearing and Settlement operations, such as EMIR and MiFID II, with the intention of ensuring these regulations are practical, appropriate and effective.
At the first meeting, we covered the four big topic areas of Regulations, TARGET2 for Securities (T2S), Giovanni’s barriers and Standards.
In the first discussion:
debated the impact of regulations on post-trade operations and IT, particularly with regards to OTC Derivatives clearing.
This is the core of the European Markets Infrastructure Regulation (EMIR) developments in Europe.
EMIR is part of the EU’s regulatory response to the global financial crisis and has a two-fold purpose:
David, Andrew and Karl discussed this in depth under the Chatham House Rule, so I can’t quote their words here. There was also a lively debate with the audience, and the net:net is that there’s EMIR, Dodd-Frank, MiFID II, Vickers, Volcker and more coming into force today.
All of these affect clearing and settlement but none of them are joined-up and, in many instances, it’s more putting the cart before the horse as we’re implementing huge post-trade changes before the basics are agreed and implemented.
The basics being Basel III – the rules for capital which will impact all of the ways in which banks collateralise and leverage their future operations.
In addition, the rules of EMIR appear to be too prescriptive. We’ve moved well away from the days of principles-based regulation and the Napoleonic rules now seem to apply.
Notably, regulations are far more in vogue today too – gone are the days of Directives – and no-one seems to have worked out (a) will the regulation work to address the issues it seeks to address or (b) how much it will cost to implement these changes.
These are the things that the Working Group will debate as we look at Risk and the first Subject Group spinning out of the CAS-WG meeting is a Regulatory Group.
The CAS-WG Regulatory Subject Group will focus upon interpreting the implications of EMIR on the clearing and settlement technology infrastructures of the City and Europe, and will work closely with other groups such as ISITC’s Working Group which focuses on the impact on operations of new and changing regulation and legislation.
In the second panel:
discussed the latest position and situation of TARGET2 for Securities (T2S).
T2S is one of the largest infrastructure projects launched by the Eurosystem so far, and hopes to bring substantial benefits to the European post-trading industry by providing a single pan-European platform for securities settlement in central bank money.
The system is due to go live in June 2015, several years later than originally envisioned but this is because the program is far more ambitious and challenging than first imagined.
As a result, there’s some doubt that June 2015 will be achieved, although the panel all concurred that T2S would go live one day – probably around 2018 – as it will force through change that is necessary if Europe is going to be efficient and effective.
Namely, it will force the Central Securities Depositories of Europe to compete and no longer be protected by national boundaries.
Part of the discussion got into the pro’s and con’s of T2S, with a clear plus being that it is multicurrency. T2S will process not just euros, but also Danish Krona and the Romanian Leu. Shame that GB pounds sterling isn’t included.
Another T2S pro is that it may be a hammer to crack a nut, considering the cost of its development and deployment, but the hammer is a worthy cost as T2S ensures that many of the Giovannini barriers are removed.
Having said that, one of the con’s is that T2S does not incorporate Corporate Actions, but then that’s partly because these are also part of the Giovannini barriers as discussed in the third panel which comprised:
There are 15 major barriers to create a transparent, seamless, pan-European clearing and settlement market that were originally identified by the Giovannini Group, which was chaired by Alberto Giovannini who released their final recommendations in a detailed report in 2003.
T2S will solve six of the barriers:
and five are being addressed by legal changes already in play through Directives and Regulations, such as MiFID II and EMIR.
That leaves four which are here to stay as they are too politically charged to change. Most of these are around Company Law and fiscal policies for example, which is why Corporate Actions is missing from T2S and most discussions of European Clearing & Settlement standardisation.
However, when the panel got into the meat of the discussions, it turns out that the Giovannini barriers are no longer relevant anyway as technology, regulatory and market changes are creating a transparent and seamless pan-European clearing capability, regardless of the national borders and barriers.
This would certainly be true if German companies could post their securities settlement through CREST for example, but that’s barrier number nine which discusses the national restrictions on the location of securities. Until that barrier is solved, even with all the technical will in the world, pan-European processing is not going to be possible.
This led to the final debate around Standards with:
This panel agreed that standards were being resolved across global markets through things like the investment roadmap.
The investment roadmap affirms the commitment of each organization (FIX, FpML, SWIFT, XBRL, ISITC and FISD) to the ISO 20022 business model by laying the groundwork for defining a common underlying financial model and ensuring some level of interoperability by producing a consistent direction for utilization of messaging standards and communicating that direction clearly to the industry.
A key to ensuring this roadmap works is that the regulators are behind it, as global markets cannot be globally fragmented and if global standards avoid global fragmentation then that’s in the G20’s interest.
That is why a shared business model with a shared vocabulary is so important.
There was a little scepticism in this context as UNIFY and other projects have tried to do this in the past, but the regulatory stick is a key one.
If the markets cannot standardise voluntarily in the way they want, then the regulators will force it through in the way they might not want.
This is why the CAS-WG concluded with a call to action through the creation of a number of specialist Subject Groups, facilitated by the Realization Group.
Anyone can be a member of a Subject Group and anyone can suggest areas that the Subject Groups should focus upon.
At the inaugural meeting, five Subject Groups were suggested, themed around the following areas:
These are not specific, limited or exclusive, and there may well be others you believe should be included. Just let us know what they are, and whether you would like to join them.
There are also a number of Subject Groups already in existence with other organisations.
For example, the Realization Group established the Counterparty Default Management Working Group.
The Counterparty Default Management Working Group has a range of objectives, namely to:
ISITC also have three key groups in existence today.
CAS-WG believes in supporting these groups, rather than reinventing them, and hence the regulatory group suggested at the inaugural meeting we will integrate with the ISITC program wherever possible.
We also expect that these groups will report back their activities to the CAS-WG at the next plenary meeting, which is planned for late Q2 2012.
If you would like to be involved in any of these Subject Groups, or want to suggest other Subject Groups, please let us know.
As can be seen, this is just the start of a process and we now need to discover if you have the appetite to get involved. We will advise all concerned of the progress of these discussions, the dates for meetings of the Subject Groups and the next plenary meetings as these are agreed, and all other dialogue around the development of the CAS-WG.
Please bear in mind one key thing: this is your group. You shape it, you form it, you develop it. Nothing is fixed at this stage, so please let anyone who has an interest in clearing and settlement know about the CAS-WG so that, over time, we can develop a clear mechanism of feedback to the regulatory authorities in London and Brussels of the development of new regulations and their impact on our technology operations.
Finally, we aim to run the CAS-WG so that attendance and involvement is completely free and open. As participation is intended to be free, we aim to cover the costs of running the CAS-WG through sponsorship. Sponsorship is open to any organisation that wishes to be seen as a thought-leader in this area, or who wishes to engage and influence the market participants outlined above. If you are interested in sponsorship, please let us know.
The Financial Services Club is launching a Clearing & Settlement Working Group (CAS-WG), in partnership with the Realization Group, with first sponsor BT.
The Clearing & Settlement Working Group: Terms of Reference
The aim of the CAS-WG is to debate and discuss all aspects of clearing and settlement infrastructures and processes. The organisation and operation will be similar to the MiFID Joint Working Group and its Subject Groups that operated in the build-up to the implementation of the Markets in Financial Instruments Directive (MiFID), with the intention of bringing together the top industry standards bodies, trade associations, infrastructures, investment firms and companies involved in Clearing and Settlement.
The CAS-WG will provide an opportunity for open discussion and debate amongst senior market practitioners and service providers on issues affecting Clearing and Settlement.
More importantly, the aim is to create multiple specialist groups that will work on specific areas of interest – standards, technologies, reference data, custodial services, etc – between each of the main plenary meetings of the CAS-WG.
Specialist Subject Groups
The subject groups and their subject headings will be determined at the inaugural meeting on 29th February. Anyone who wishes to propose a group, lead a group or be a member of one of the groups can volunteer their participation and input at the inaugural meeting.
The subject groups will be facilitated through support from the Realisation Group and any organisation that wishes to be involved can propose their support before, during or after the inaugural meeting.
We believe that these subject groups are particularly important today as Clearing & Settlement, and in particular Clearing, will be massively impacted by new regulations being drafted and implemented across the world such as Basel III, Dodd-Frank, the Vickers Report and the MiFID II.
The aim of the subject groups is to provide specific input to the regulatory bodies – including the FSA, its successor bodies the PRA and CBA, and Michel Barnier’s team in the European Commission – on the business and technology implications of implementing the regulations in draft and final form, with the intention of ensuring these regulations are practical, appropriate and effective.
The output of the subject groups therefore will be actions that are clearly practical about the details of the impact of new regulatory developments upon clearing and settlement operations, infrastructures, standards and technologies.
The first meeting will be held at BT’s offices in Newgate Street on the afternoon of February 29th where we will have four panels discussing:
Registration starts from 13:30 and the first meeting will begin at 14:00 with panellists from clearing and settlement infrastructures, investment firms, standards bodies and industry associations and more attending.
After the meeting on 29th February we expect to have quarterly plenary meetings thereafter to update members on the sub-group activities.
There will also be regular subject group meetings, the number of which will be dependent upon the outcome of the first meeting.
Membership of the CAS-WG
We aim to run the CAS-WG so that attendance and involvement is completely free and open. It is also aimed to be inclusive of all participants in Clearing and Settlement operations.
Attendees and active members are expected to be from all parts of the financial industry – buy side, sell side, exchanges, CCPs, CSDs, standards bodies, solutions providers, technology providers, telecommunications, consultancies, law firms, accounting firms and more.
As participation is intended to be free, we aim to cover the costs of running the CAS-WG through sponsorship. Sponsorship is open to any organisation that wishes to be seen as a thought-leader in this area, or who wishes to engage and influence the market participants outlined above.
To register to join the inaugural meeting or if you are interested in sponsorship opportunities, send an email to email@example.com.
 The MiFID Forum is made up of the top industry standards bodies and trade associations (namely, SIIA/FISD, FIX Protocol, ISITC Europe and TWIST) affected by the European regulation, Markets in Financial Instruments Directive (MiFID).