We wrote a few weeks ago about incoming changes to how firms access their FCA systems to upgrade data protection. You can read that article here.
The new system will replace the current 6-digit passcode with the user needing to log in using a One Time Passcode (OTP).
The implementation date of 20th January has now been delayed until Thursday 2nd February.
We will provide further updates as and when these are available.
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A temporary solution if there are problems obtaining an LEI in time for any affected transactions from 3 January 2018.
There are some apparent anomalies in the rules. We have obtained ‘clarification’ from the FCA.
The FCA has clarified some aspects of how the recording rules will apply to firms that are not Article 3 Exempt.
How will changes to compliance governance affect your company?
MiFID II – Aggregated costs disclosure
Alistair MacDougall Compliance 2017, 2018, 2019, MiFID, PI
This new requirement is posing some questions about how it can best be implemented. We think that firms should wait until the mechanisms in the market place are a little clearer.