MiFID permissions and notifications checklist

FSA has issued a guide to help firms determine the MiFID-related notifications and applications, including variations of permission (VoPs), they should make in time for Directive implementation on 1 November 2007. Many firms, will see their permissions adjusted and passport notifications generated automatically by the regulator but where this does not happen the guide sets out submission deadlines, the general target date is 1 August 2007. This date applies, for example, to firms that wish to make changes to their client categorisation for MiFID business, to reflect the slightly different classifications in the Directive (retail, professional and eligible counterparty) from the existing definitions (private, intermediate and market counterparty) in the FSA Handbook. Non-MiFID operations will be able to use the current criteria for customers up to 1 July 2008 but should apply for variation of permission by 1 January next year if they are unable to map the services offered to different classes of client directly on to the new MiFID categories.