As the November MiFID deadline looms, investment firms in the City and across Europe are working hard on getting their systems ready for the new regulations.
Speaking at a Securities & Investment Institute conference in London, Patrick Ludden, MiFID (Markets in Financial Instruments Directive) programme project manager at Barclays Capital, said the focus of his team so far has been "about turning the directive into a practical beast".
He said the short timescale until implementation is "a big headache", making programme delivery a top priority for senior management.
The big challenge with MiFID is the directive's sheer breadth of scope, as changes affect markets, clients, regulators and internal operations, he said.
One of the main focuses for Ludden and his team now is defining the business requirements for the IT department — which they aim to complete by the end of April.
The next eight months are going to be very busy.
He said these requirements need to be defined as soon as possible to enable the IT department to deliver the appropriate systems in time.
Ludden described the technology changes for MiFID as "small and messy", with some much needed technical detail still not available.
To deal with the broad scope of MiFID, the bank has created 13 teams charged with looking at its impact on the different business areas within the organisation.
The groups report to a project management office which meets weekly and, in turn, reports to a steering committee which meets monthly.
The bank is working across the industry with regulators and other banks to discuss common concerns — the data field included in client confirmations, for example.
But Ludden is confident compliance by the bank is still achievable in time for 1 November, although he admitted: "The next eight months are going to be very busy."