MiFID II Update – EMT Template V3 – Preparation and new business considerations
By Anthony Miranti, FundConnect's Head Of Business Development
The European MiFID Template (EMT) has been a successful industry endeavor within the sphere of data standardization and is once again evolving to take account of the operational and business experience that has been garnered since its inception. While the EMT V.1 is still in use and the EMT V.2 was adopted and utilized primarily for structured products, a new version of the EMT, this time Version 3 is in the final stages of approval and FinDataEx (who serves as the working group for the definition of the EMT) expects that it will be slated for final implementation in October 2020.
What is different about the EMT V.3?
First of all, there will be changes in the template itself, including the addition of new fields, along with changes in some of the existing field names and data syntax as well as new designations of what is optional, conditional, indicative and mandatory. The final approval of the template is expected to take place in the nearest future.
While the changes in the template and the data content is on the radar of most stakeholders, the real decisive novelty in connection with the release of the EMT V.3 relates to the business practices and data exchange elements that will need to be addressed in order to facilitate and support business activities for both distributors and asset managers.
For example, there will be a new reporting philosophy, in that separate subsets of data will be able to be reported as changes are made in any of the three sections, which are broken down into Target Market Data, Ex Post Costs and Ex Ante Costs. This will allow distributors to pinpoint relevant changes and to only update the relevant sub-template in their databases.
As stated above the final implementation of the EMT V.3 is scheduled to be finalized in October 2019 with implementation and roll out in 2020, but it is expected that in the first half of 2020, that different actors could be working with V.1, V.2 or V.3 at any given time. Thus, the fact that neither asset managers or distributors will all be aligned in their preferences or implementation timelines, there will need to be a common industry focus on taking account of the individual implementation timelines and technical work will need to be performed in order to consolidate the data coming in, in different versions, and ensure that data is being delivered in a uniform fashion to consumers.
Although the implementation timespan for EMT V.3 is somewhat lengthy, asset managers should be aware distributors will start pushing for the new version, as soon as they have performed their own technical implementation.
EMT Template Version 3 Public Consultation
FinDatEx (Financial Data Exchange Templates) published a public consultation related to the EMT Version 3. Comments can be sent to [email protected] until the 1st of November. The template draft and more information can be found here: https://www.findatex.eu/work-in-progress.