Today is the day. After TEN YEARS of speculation, scepticism and scuffling… MiFID II (Markets in Financial Instruments Directive II) has come into effect. Or has it? You can’t help but feel it’s somewhat of an anti-climax. Not long after the triumphant early headlines, we saw the first waves of “half of UK businesses admit they don’t know the MiFID II deadline” and “Exchange giants land last-minute breather on MiFID II”. While the first is arguably an opportunistic and painstakingly crafted PR survey headline, the second highlights just how difficult it is to enforce a regulatory deadline of this scale.

The Daily Telegraph reports that the FCA only let these two London-based houses off the hook on the morning the rules were due to launch – so today. Which if I was feeling unkind, would say sounds a little like the NHS ‘crisis not crisis’ as it announced its decision to continue the continued postponement of all non-emergency surgery until the end of January (at the beginning of January). It just doesn’t look all that, well… organised. Moving a deadline on the due day is sort of “the dog ate our homework” and “oops, we missed it.” Of course, this is an over-simplification of a huge amount of complexity at play, but you get the idea.

Which reminds me – I was at a drinks party between Christmas and New Year, (made up mostly of my parents friends), and happened to mention this regulation to someone in the context of what I do for work. (I promise the rest of the party was more exciting.) He used to work for a large accountancy firm and, clutching his glass of red wine, with mince pie in hand, seemed genuinely misty-eyed with nostalgia as he exclaimed, “Two! Ah, I remember MiFID One”. Much like recalling a boisterous but lovable old Labrador that has since been replaced with a newer model puppy.

So when a young financial buck gazes up at me in 20XX, and asks “where were you when… MiFID II came into play?” I shall answer – at my desk, with a cup of tea, fruit gums, and a terrible cough.