MiFID II Implementation Reviews

With the introduction of MiFID II in January 2018, firms should now be fully compliant with all applicable requirements.

Due to the complexity of the requirements, and the fact that some of these were linked to an annual cycle, many firms’ initial implementation projects extended well into 2018 and early 2019.

For example, for many firms, the first full set of annual costs and charges disclosures were only recently completed, along with the completion of the first Research Payment Account budgeting and disclosure cycle, and the consents/disclosures of budgets for the next period. The RTS 28 disclosures for the first year fully within scope of MiFID II requirements were due in April 2019.

This means now is the time to take a step back from initial implementation and gain assurance that this complex regulation has in fact been properly implemented.

While generally more onerous for sell-side firms, the requirements on the buy-side are in some areas less well understood, as the regulations were not written or tailored with these firms in mind, and in most cases the guidance available is from the sell-side perspective only.

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Learn more about how we support financial services firms' global regulatory, operational and governance needs.

Darren Mooney

Partner and Co-Head of Business Development

Darren Mooney is a Partner and the Co-Head of Business Development at Greyline. Before joining Greyline, Darren served as deputy chief compliance officer of Partner Fund Management where he held primary responsibility for the compliance program of the second-largest hedge fund in the Bay Area. Prior to that, Darren spent five years providing compliance consulting services at Cordium and then ACA Compliance Group, where he led the company’s San Francisco office and west coast operations. In addition to providing ongoing consulting services to a variety of investment managers, including hedge fund, private equity, venture capital, real estate, quantitative and other wealth managers, Darren also regularly guided clients through the SEC registration process, implemented tailored compliance programs, supported clients’ live SEC exams, and served as an SEC-mandated independent compliance consultant following an SEC enforcement action. Darren’s other experience includes serving as deputy chief compliance officer and associate counsel at F-Squared Investments where he directly supported the compliance program during the investigation and subsequent enforcement regarding historical advertising practices. Darren has a B.S. in Economics from the University of Delaware and a J.D. from Suffolk University Law School. He is a member of the Massachusetts bar.

Annie Kong

Partner and Head of Venture Capital
Annie Kong is a Partner and Head of the Venture Capital Division at Greyline. She provides ongoing compliance consulting to investment advisers and manages client relationships. Prior to joining Greyline, Annie was part of compliance and operations at a long-only manager-of-managers that advised pension fund clients. While there, she conducted compliance and operational due diligence on SEC-registered investment advisers on the platform. She also oversaw and counseled on various legal matters across the firm. Annie has a B.A. in Economics from the University of California, San Diego, and a J.D. from the University of San Diego School of Law. She is an active member of the State Bar of California.
Greyline is pleased to announce that we are the recipient of the 2021 HFM U.S. Service Award in the Best Technology Firm – Newcomer category.