Our Services

Our USP is the combination of a deep regulatory knowledge built up over the last 18 years, layered with over 40 years of OTC markets business management. This provides an interpretation capability that not only explains the regulatory impact but also allows actionable plans to be laid.

Strategic Planning

Typically over a day or two the board or similar senior business management will review the longer term impacts of regulatory or other change such as:

  • Increased capital cost / balance sheet impact (clearing, margin on non-cleared trades, operational risk model, credit)
  • Market shift from principal to agency model
  • Refining the Best Execution Policy
  • Best practice ethos. Fundamental change in sales/client and sales/trader relationship
  • Building out a secondary trading market
  • Planning for an educational programme across the markets


This allows the firm to decide how best to position the business and markets, not only to survive but also to take advantage of relative strengths under the new market models. This exercise is a vital first step in wider initiative planning. If the overall plan does not consciously direct the business towards the anticipated market and business structure, the firm's regulatory development could deliver a set of unaligned controls and restrictions that do not allow the firm's business to operate efficiently within the new market structures.

Implementation Planning

Having taken a strategic view on the future business model and related appropriate regulatory approach, the next step is to define both the existing baseline and the set of required goals. Part of that analysis should also establish the work streams that will be necessary to meet the defined goals. The importance of this step cannot be over-emphasised. Without sufficient preparatory analysis the work that will be undertaken faces a severe risk of either missing a vital element from the execution or setting off a work stream towards an incorrect destination.

Implementation

Most institutions will currently find themselves in the middle of this phase, having taken an initial approach to impending regulation or remediation of an infraction. Perhaps the planning team has set out implementation goals and over a phase of many months the systems and surrounding processes will be put in place to conform to the new requirements. It is vital that any decision rights, accountabilities and authorities are established at the start, rather than half way through a process when a challenge arises. 


Given the typically long timeframe for this development cycle, it is important to establish plans with full knowledge of the regulatory requirements and to ensure a regular review with the relevant industry / regulatory expertise. Details and timings can often change mid-cycle, so ensuring the plans remain aligned to both the strategy and subsequent regulatory changes will save precious resources and funding in the long run.

 

The surrounding development work is normally in IT speak; a 'non-trivial' development plan. Often the work has had to start before the final regulatory outcome is completely defined. For instance, often the development will have started before the final technical rules have been finalised by the authorities. Whilst the wider outcome may be well understood, the finer details often require final definitions in several key areas. Taking a step back to the first stage to undertake a strategic review is often a sensible idea, if only to ensure that the development plans will deliver on what has now become the expected outcome.



Making it Real

Appropriate planning is recognised as having a significant impact on the outcome of any development initiative. However there comes a point when the planning must become real.


Having planned carefully for impending regulations - whether it was MiFIR, an approach to meet the requirements of the FX Global Code or how to implement change in a local marketplace - the implementation stage is absolutely key.


Whether or not FMR Advisory has helped in the preparations to this stage, we are able to take an active role in the implementation of your plans. Embedding us in the business for a defined timeframe will ensure a solid start to your implementation, with management lead being delivered by a regulatory specialist.


The team can be built out either from internal resources, third party contractors, or our network of regulatory specialist contractors.