ESMA Holiday reading- MiFID\MiFR latest consultations

As an early Christmas gift to European financial lawyers (and presumably their opticians as well) ESMA has today published a Consultation paper on MiFID II\MiFIR and a Consultation paper Annex B on their respective RTS. In combination, the two papers total 1165 pages, the deadline for submission of responses is 2 March 2015.

While the public appetite for banker\lawyer laments is unlikely to be high, the estimated 50,000 financial regulations since 2008 represent a barely-scalable barrier to entry for new participants and a huge disincentive for all but the largest firms. Even the TBTF behemoths, ensconced in their fortress of paper, run an increasing risk of falling foul of regulations whose sheer volume impedes comprehension and implementation.