FSA has published a review of its work to see how wholesale investment firms have implemented MiFID. Its review covered its defined wholesale priorities of:  

  • best execution;
  • inducements;  
  • investment research;  
  • client classification;  
  • conflicts of interest; and  
  • senior management systems and controls.  

On the whole, it was happy with how firms had dealt with the changes. However, it noted firms seemed to find the inducement rules confusing. Also, execution policies were often not helpful and firms had trouble dealing with prior express consent requirements.