OREPA - a Practical Approach to Client "Repapering"

 

At the time of drafting (June 2006), exactly how individual Firms should interpret the various MiFID directives continues to cause frustration and concern, primarily because of the lack of clarity, even on issues such as whether or not all clients will require new order execution policy documents (generally known as "repapering") in order to comply with the relevant MiFID articles. The FSA appears to be taking the interpretation that some repapering will be necessary. However, for many Firms, determining exactly which clients need to be repapered might be just as much of an expensive headache than going for the less ambiguous option of getting all clients re-contracted in order to put MiFID compliance in this regard beyond doubt and avoid potential weaknesses and legal concerns following MiFID implementation in November 2007.


Lexington has developed OREPA - Order Execution Policy Application, a solution which will benefit any Firm undertaking a non-trivial repapering exercise. By using OREPA, your Firm will be able to carry out the project:

 

·         in a simple, structured and controlled fashion

·         with a high degree of certainty over the results

·         using inexpensive communications means wherever possible

·         in a way which offers scope for further managed two-way communication with clients

·         for those clients which you choose to handle through OREPA, you can be assured of being provided with ample information to demonstrate MiFID compliance to the FSA.

 

OREPA provides all the functionality necessary to enable a Firm to ensure that all relevant clients are issued with and sign the Order Execution Policy Documents required under the MiFID guidelines. It handles the issuance and tracking of each document to ensure that all signed documents are in place by the MiFID "go live" date.

 

OREPA is an Intranet application that contains two main functional areas:

 

The Internal Application - Access to which is restricted to the relevant Firm's employees, and which contains the various client communications and administration functionality. This part of the application also contains the required interface to the Firm's Client Static Data database.

 

The Client-Side Application - To which all relevant clients have access, and which contains a limited amount of functionality enabling clients to gain access to relevant documentation and facilities to communicate various elements of information to the Firm.

 

All Lexington's business applications in this area are all being developed in conjunction with our partners at OCEAN, using their Rapid Application Development environment for interactive web-based business applications. This is the technology that allows us to roll out tactical solutions quickly and effectively across the client's enterprise using standard browser technology.

 

Needless to say, OREPA is powered by OCEAN!

 

Related Lexington Service Offerings:

Regulatory Change

Regulatory Documentation Portal - The RDP

MiFID Solutions

Web Applications - OCEAN

 

© Lexington Systems Limited 2006