January 4 was the first day Hof Hoorneman Bankiers, like other financial institutions all over Europe, had to report their transactions to the regulator under the new MIFID ii regulation. Hof Hoorneman Bankiers is located in the Netherlands and is an independent bank with full banking license. The bank has been an investment manager since 1989. Hof Hoorneman has 60 employees and the managed assets are approximately € 2.1 billion.
Sven Schuling, IT Director at Hof Hoorneman, shares some insights about Hof Hoorneman’s MIFID ii implementation.
What does Hof Hoorneman have to do under MIFID ii?
Hof Hoorneman has to comply to the new rules for Investor Protection, Record Keeping and Transaction Reporting. This means much more information has to be stored about investment decisions, clients and the actual trades. Existing workflows have to be changed for this.
How did you prepare for MIFID ii?
KPMG helped us by identifying the impact and the gaps, we started with this in 2016. The technical implementation was done using our current systems. Information Builder’s WebFocus was used for gathering all information. We’ve implemented transaction reporting using DEX Regulatory Suite of DEX Data Explorers.
What was the impact for clients, organization and IT?
A lot of processes had to be changed, and we had to collect LEI’s and ID’s from our clients.
What were the biggest challenges?
First of all it was hard to get all requirements clear, because it is so much. The next challenge was gathering all client data, like LEI-codes and ID-cards.
Furthermore it was difficult to establish general rules for which financial instruments had to be reported. We’ve solved this by recording per ISIN-code if this instrument has to be reported or not.
The whole market is used to completing processing of trades on day+2, but MIFID transactions have to be reported on day+1. This causes some challenges too.
Did you succeed in reporting in time?
Of course we did.
How do you feel about the way things went?
This has been a very time and resources-consuming operation, but we succeeded.
What are the next challenges for you?
New regulations we have to implement are the Deposit Guarantee Scheme and GDPR. Furthermore we would like to spend more time on servicing the business!