Leverage automation and outsourcing with regards to per-client adherence.
Outreach-oriented regulatory tools and services can facilitate the terms-adherence process across a dealer's client base. Capabilities that include furnishing a pre-existing database of regulatory-relevant client representatives; providing centralised tracking for outreach personnel; sending auto-generated follow-up emails to unresponsive clients; generating rules-based system prompts for clients to upload specified types of supporting materials, where needed; and provisioning of customisable, client classification-specific terms to be sent out form elements of an effective terms-repapering solution. Additional features including e-signature capability and centralised client query entry enhance the client experience, and further support terms adherence.
Provide transparency to clients.
Some clients will use this as an opportunity to re-open the entire customer agreement. However, to meet the deadline, provide your clients with transparency into what is required to achieve compliance with the Directive, and why specific terms must be updated.
Adopt a phased approach to terms-adherence.
Rather than outreaching to all clients in one attempt, begin the outreach for terms adherence in waves of clients. The inputs for client segregation into waves of outreach will vary per dealer, and are likely to include considerations such as revenue-generation impact of the client, existing client classification, and the likelihood of a particular client segment wanting to negotiate away from stock terms.
Terms-repapering will be a significant undertaking for all investment firms subject to MiFID II adherence, more so for dealers where the client base is substantial. Firms need the right technological tools and appropriate client data as well as client contacts in place to expedite this task. This, coupled with well-trained staff and a carefully-planned approach, will help to lighten the load.
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