MiFID impact map for a mid-tier investment bank’s UK operating units

A mid-tier international bank needed a clear view of MiFID’s regulatory, IT and business impact across its UK operating units — including investment banking, treasury and specialised finance, and private banking — and the branch activity it maintained elsewhere in the EU. Without a shared heat map, management actions and programme design would fragment by desk.

GRT completed the impact analysis across five UK operating units. We ran awareness workshops, built heat maps of MiFID impacts by operating unit across thirteen work streams, produced impact reports per unit, and identified the management actions that followed. We also designed a high-level project plan and the overall programme structure so the bank could move from analysis into delivery on one spine.

GRT left the bank with a single impact picture it could govern: heat-mapped effort by unit and lifecycle stage, data-architecture and reporting templates for best execution and transaction reporting, and a programme shape ready for build — rather than a stack of siloed workstream notes.

Illustrative outputs from the impact programme: operating-unit heat maps across the trade lifecycle, a front-office data-flow template for best execution and reporting, and an RTS 27 field-source map for management actions.

MiFID impact heatmap — Level 0 overview

Gaps and relative effort across operating units and the trade lifecycle (illustrative programme view)

GRT ConsultingGovernance · Regulation · Technology
Highest potential effort
High potential effort
Moderate effort
Limited effort
Workshops → OU heat maps → management actions
Operating unit Pre-trade Trade Post-trade Monitoring & data
Client onboarding Sales / origination Pricing Order initiation Order execution Risk mgmt Booking / routing Affirm / confirm Clearing & settlement Business mgmt & reporting
Equities
  • Client classification · ToB repapering
  • Inducements · research access
  • SI quotes · RFQ store
  • Algo ID · circuit breakers
  • Best ex flags · venues
  • Risk limits feed
  • Order / trade enrich
  • Extra report fields
  • SSI / STP checks
  • Product governance · best ex · conflicts
Fixed income
  • Classification · suitability
  • RFQ capture
  • Quote store for best ex
  • Voice order timestamps
  • Venue / SI path
  • Position risk
  • Deal capture from enquiry
  • Confirm enrich
  • Settlement data
  • Remuneration · inducements · PnL for research
FX
  • Client class refresh
  • Voice / e-RFQ
  • Market quotes
  • Timestamp pack
  • Execution venues
  • Market risk
  • Booking STP
  • Confirm / affirm
  • CLS / settle
  • Best ex reporting · complaints
Commodities
  • Onboarding refresh
  • Origination controls
  • RFQ tooling
  • Algo / DEA where used
  • Execution monitoring
  • Risk
  • Booking
  • Confirmations
  • Settlement
  • Governance · conflicts · best ex
Structured products
  • Complex product class
  • Target market · costs
  • Pricing disclosure
  • Order data pack
  • Execution quality
  • Risk
  • Booking enrich
  • Confirm / KID links
  • Settlement
  • Product governance · costs & charges · inducements
Illustrative anonymised view for a mid-tier investment bank MiFID impact programmeGRT Consulting

MiFID front-office data architecture

Generic data flow — quote / order capture through to best execution and transaction / trade reporting

GRT ConsultingGovernance · Regulation · Technology
Data inputs    Data outputs / reporting feeds
Voice or electronic client communication
Manual / electronic quote & order capture
Front-office / deal systems
Message automation / enrichment hub
External vendor
best-ex monitoring
External vendor
best-ex reporting

RTS 27 quarterly publication pack
Transaction reporting
data (T+1)
Trade reporting
within 15 minutes

Additional
client data
Additional
product data

Working assumptions

  • London-booked activity can be identified cleanly.
  • RFQ / voice capture stores instrument, size and required timestamps.
  • Electronic RFQs persist the same data set.
  • Non-executed quotes and orders need durable storage.
  • Reporting extracts focus on client-facing activity, not hedges.
  • Quote capture may start as a parallel control before full STP.

Key implications

  • STP matters more once capture and post-trade clocks tighten.
  • Deal capture should start at client enquiry to avoid double booking.
  • SI quote obligations need client, instrument and APA transmission path.
Illustrative architecture template used in MiFID impact analysisGRT Consulting

Tables required for best execution reporting (RTS 27)

Sample daily instrument pack — field sources mapped for impact analysis

GRT ConsultingGovernance · Regulation · Technology
TR Transaction reporting data
QCT Quote / order capture
BEM Best-execution monitoring
Tables 7 & 8 not applicable in this template

Table 2 — Instrument identification

Field Source
Description TR
Identifier (ISO 6166) TR
Classification (ISO 10962 CFI) TR
Currency (ISO 4217) TR

Table 4 — Daily price information

Field Source
Simple average transaction price TR
Volume-weighted transaction price TR
Highest / lowest executed price TR

Table 3 — Intraday price information (repeat per instrument / day)

Time point Avg executed price Total value First trade after T Reference price
09:30 · 11:30 · 13:30 · 15:30 TR TR TR price, time, size, system, mode, platform BEM

Table 5 — Costs and charges

Field Source
Link to costs disclosure Static
Total value of costs Assessed in impact analysis

Table 6 — Likelihood of execution

Field Source
Orders / RFQs received QCT
Transactions executed · value TR
Cancellations · modifications QCT
Median size · market makers TR / QCT

Table 9 — Extra RFQ information

Field Source
Mean / median time acceptance → execution QCT
Mean / median time request → quote provided QCT

Impact analysis maps which operating units already hold TR / QCT / BEM data and where capture or vendor feeds must be built.

Illustrative RTS 27 data-source map for MiFID programme designGRT Consulting
GRT Consulting

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