FSA to gold-plate MiFID systems and controls rules

In its MiFID implementation consultation paper on organisational systems and controls, the FSA proposes to establish a “unified approach” to introducing systems and controls rules for those firms subject to MiFID and for those subject to the Capital Requirements Directive (CRD). This “common platform” approach is designed to make it convenient for firms subject to both directives as they will only need to apply one set of rules. But the FSA admits: “Our proposal to establish a unified approach to systems and controls requirements for firms subject to CRD and/or MiFID will involve some...