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MiFID II will enter into force on 3 January 2018 and brings with it a steep increase in mandatory reporting volumes as well as changes to product governance and investment advice. Only weeks before the official entry date, organizations are struggling to find an effective way to increase the knowledge level in their teams and reach the level of preparedness they will need to satisfy their clients’ needs from January onwards.
Well aware of the challenges linked to regulatory training, the CSSF addressed the specific MiFID II training requirements in Circular 17/670 on 13 October 2017: Trainings on the basics of MiFID II, AML, MAD/MAR, Financial Markets—and on a broad set of other topics related to banking products and processes—are to be undertaken by employees to ensure compliance with the new directive. With this upskilling of professionals across banks and financial institutions, the new legislative framework sets out to strengthen investor protection and ensure greater transparency in financial markets.
The Circular establishes that professional institutions can train their employees and assess their knowledge internally according to a formalized procedure. Alternatively, institutions can ensure that their employees attend a training provided by an external service provider that offers a training curriculum certified by the CSSF. A combination of these two approaches would also be possible. The Circular furthermore indicates the minimum training requirements and suggests ways to assess competencies and knowledge.
Deloitte has been listed by the CSSF as an organization that delivers an external training program in line with these requirements of the CSSF Circular. In the context of MiFID II, Deloitte’s D.Learn blended learning offering combines standardized e-learning modules on the basics of MiFID II and its related topics, with classroom sessions on bringing MiFID II to life, tailored to banks’ and other financial players’ specific processes and products.
Some financial institutions choose to partially train their employees internally, and complement their own training sessions with D.Learn to fill specific gaps in their regulatory learning curricula. In such cases, Deloitte supports its clients in setting up a formalized procedure to assess the competencies and knowledge of their employees, meant to be controlled a posteriori by the CSSF as lined out in the Circular.
If you are struggling to find the best solution to the training challenge brought by MiFID II as the days get darker and the deadline approaches, please visit our dedicated D.Learn webpage for more information about our platform and blended learning solutions. There is still time to get ready for MiFID II—if you act now.