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Nearly three quarters of trading executives reported that they are already at the implementation stage. This contrasts with the regulatory function, with only 20% stating that they are at the implementation stage, although 60% have completed an impact assessment. The operations function leads in “identifying the regulatory changes that impact the business,” with 46% stating that they have done so.
Stephen O’Sullivan, partner, Capco, says: “Institutions in both the US and the UK are expecting clarifications from regulators, but even with the ambiguity over the final rules, firms are wisely moving ahead to prepare. However, the report does reveal that implementation is happening piecemeal through task forces working at a national level, and therefore not at the necessary global, enterprise-wide level.”
It’s difficult to be strategic when the market impact of these changes is still very unclear and we would expect that near-term tactics will take the lead at most institutions.