MiFID II: What Do You Need to Know?

Sheila McGee Smith Sheila McGee-Smith is a leading communications industry analyst and strategic consultant with a proven track record in new product development, competitive assessment, market research, and sales strategies for customer care solutions and services. Her insight helps enterprises and solution providers develop strategies to meet the escalating demands of today’s consumer and business customers.

If you work in the financial services sector, you’ve likely seen news articles and heard IT, operations and other company managers and executives talking about the impending MiFID II regulation. It’s likely been a topic of conversation for months, if not years. Recently, The Washington Post began an article about MiFID II saying, “The impact of new market rules sweeping across Europe has been likened to motorists suddenly being told they must drive on the other side of the road.”

While the statement may seem like hyperbole to some, for those who work in financial services the statement will have the ring of truth. They have been working for years to create and refine practices and systems to be compliant with a European Union directive that became effective January 3, 2018: the Markets in Financial Instruments Directive II or MiFID II.

An original MiFID was enacted in 2004, prior to the 2008 global financial crisis. Ad hoc changes were made by individual countries to address issues that resulted from the crisis. These issues are being addressed through MiFID II, which harmonizes the rules for all firms with EU clients, across all countries. The main goals of the MiFID II are:

  • Customer protection
  • Increased financial product governance
  • Unbundling of advice from the sale of financial instruments
  • Broader scope of supervision to include equity and non-equity trading
  • Firms must take “all sufficient steps” to ensure that transactions are executed in the best interest of customers
  • A considerable increase in the requirements for transaction data reporting

From an enterprise communications perspective, the aspect of MiFID II which is relevant is that it requires the capture of all communications and orders intended to lead to an execution of a trade, even if the transaction is not actually finalized during the interaction.

Penalties for non-compliance are set by the regulatory agencies in each European Union country. The first fine for non-compliance of the 2004 MiFID directive was given out to Barclays for inaccurate transaction reporting. Barclays’ fines totaled £2.45 million for their inaccuracies between 2006 and 2008. Since then, published reports say that banks have paid over $204 billion in compliance-related fines and infractions.

Every day, millions of transactions are reported by hundreds of trading venues, for thousands of different financial instruments. As a result, the potential for individual company fines of tens of millions of dollars is very real.

If, like so many companies, you are not sure if your current recording procedures will be sufficient to meet the requirements of MiFID II, the time is now to prioritize an assessment. Businesses need a comprehensive review of their compliance across all channels – phone, email, and SMS – to meet the new regulations. In addition, they need to demonstrate that policies, procedures and management oversight of the MiFID II recording and monitoring rules are in place.

If this post has made you wonder whether MiFID II regulations apply to your firm or what types of transactions need to be recorded and which do not, download the white paper MiFID II: What it Means For Your Organization? It gives a more extensive review of the MiFID II regulations and answers questions about what geographies are impacted, what types of firms are affected and how the new transaction recording rules are different from the rules in effect today.

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Connected Health: The Digital Transformation of Care Innovation

All around the world, across the spectrum of disease, IT is changing our approach to chronic conditions and how we approach connected health. Text messages remind people living with HIV to take their medication and keep their medical appointments. Smartphone apps diagnose post-traumatic stress disorder by analyzing a user’s voice. Online forums enable breast cancer patients and survivors to trade information related to every stage of their care.

Collectively known as “connected health,” these recent, IT-driven innovations represent the intersection of digital technology and care. They’re transforming not only the way people manage their own health, but also the way they interact with their healthcare providers.

Unintended, but welcomed, consequences

By and large, connected health is an adaptation of technologies that were originally developed for other purposes. Mobile technology started out as a voice communication tool. Instant messaging was an outgrowth of online chat rooms. Social media became a means for making new friends.

Now these technologies have evolved and converged in a way that is overcoming formerly intractable barriers to care. By minding the agenda of day-to-day care, for instance, they give people the opportunity to stay in adherence with their treatments even where clinical visits are impractical due to cost, distance or availability. And by helping patients preserve their privacy, make sense of their conditions, and learn from others with similar experiences, health IT can lift the stifling veil of stigma from disease. 

The implications don’t stop with the individual. Connected health also helps people manage their own disease state so they don’t spread it to others. Across whole populations, it can allow interventions aimed at preventing chronic diseases, such as behavioral modifications that reduce the incidence of obesity.

Changing care innovation paradigms

In all these respects, connectivity is bringing to medicine a level of accountability and democratization that seemed unimaginable not so long ago. But it’s also dialing up the urgency of some unanswered questions. Among them:

  • What information is appropriate to gather? Not all information has value in a healthcare setting.
  • Will information remain proprietary? It’s unclear to what extent stakeholders are willing to advance the interests of the community ahead of the interests of a company.
  • What would a sharing paradigm look like? If companies were to share information, they would need a seamless, cohesive way to do it.
  • How will privacy and security be preserved? Artificial intelligence and machine learning are critical pieces of this equation.
  • How will healthcare use technologies to create new models of care? Today’s applications are largely geared toward improving quality and outcomes of existing care models.

There’s no one-size fits all solution to these questions. Neither is care innovation strictly a technology issue. Technologists must collaborate with clinicians, patients, and patient advocates to take care coordination and operational efficiency to the next level in helping people cope with long-term diseases. A new, technology-powered paradigm—one that transcends existing constraints of time and resources—can bring a welcome transformation in the ongoing management of care coordination and the patient experience.

Avaya Equinox, Now with Team Collaboration, Just Got More “Go-To”

 

I recently read that the Apple App Store now contains about 2.2 million apps. It’s an amazing number and a testament to the creativity of developers and the variety of our human interests and needs. But it made me wonder: how many apps can we really use on a regular basis & for what? Are they for fun? Are they informative? Do they increase team collaboration? If your smartphone is like mine, you’ve got a number of go-to apps that you use regularly, let’s say weekly, and probably a few you use daily or almost constantly. Then there are the Tier 2 apps, hiding in your folders that seldom see the light of day. It’s fun to delve into these folders every few months and rediscover the apps that I thought looked so interesting at the time but now languish for months on end.

What’s fun for personal apps however, can often become a nightmare in the work world. We all have someone in the office that has that need to be first with the latest hot app, to provide their take on what’s cool and what’s not and make everyone else feel a little short of the mark for not using it first. Of course most of these apps get frenzied activity for about 3 ½ days and then slip into oblivion. The issue for most of us is we simply have too much on the go to be constantly changing the way we work and coercing others to adopt our favorite app of the week.

What my work day really needs is a true go-to app. One that makes me more productive, more reachable, more on track and that lets me get to my tasks and meetings with a single touch. If you’ve read my previous blogs, you know where I’m going with this: my go-to app is Avaya Equinox®. With its “mobile-first” Top of Mind screen, it provides me with at-a-glance visibility to meetings, instant messages and my call history giving me a single place to keep up to date and productive regardless of where my day may take me.

I’m happy to say that my go-to app just got more, well, “go-to”. The Avaya UC experience that I rely on every day is now being extended with the integration of a cloud-based team collaboration capability.  It gives me the full benefits of a team work environment that integrates voice, video, persistent team chat and messaging, along with file and screen sharing, all from within the Avaya Equinox experience.

Let me give you an example of these new Equinox team collaboration capabilities in action. I’m currently working with an external vendor on a major project. Our work will carry on for several quarters with new materials being created that need review, discussion, and likely several rounds of back and forth. To get the project kicked off and a vendor selected, we needed the full gamut of collaboration capabilities from simple voice calls to several all-day video conferences with participants joining from around the world – something easily managed with Avaya Equinox. 

The next step was to establish a core team and shift into a regular cadence of interaction. Adding the participants to the team collaboration space from both inside and outside Avaya was a snap and we were instantly able to communicate with one another – I use one to one instant messaging for small items or questions and chat when I want to involve the entire team for broader issues. Tasks get assigned within Avaya Equinox to keep our review cycles on track and we use the file sharing capability avoid clogging up our email. If I’m off line at some point, due to travel or other activity, a quick glance at Avaya Equinox gets me back up to speed with the team’s progress.

On a weekly basis, we usually need some face time, and Avaya Equinox provides complete meeting capabilities including audio / video conferencing with screen sharing so we all gain the advantages of personal interaction. No matter where we are or what we are doing, we can all collaborate on content in real-time – it’s more productive and prevents misunderstandings across a widely distributed team. 

In many ways our team collaboration space has become a virtual “war room”.  Information is clearly visible and easily shared, I can see who’s available at any time and formal and informal discussions can be initiated with ease.

There’s no shortage of apps available to anyone with a mobile device and the time to spend browsing around an app store. The real challenge is finding those few go-to apps that you’ll use every day. If you aren’t using Avaya Equinox yet, I’d encourage you to give it a try. I think it will make your short list of “go-to” apps and in a month or two, you might wonder how you got through your day without it!

Building SMS Text Bots is a Breeze

As a nerdy guy, I love movies about other nerdy guys. Give me movies like “A Beautiful Mind,” “The Theory of Everything,” or “Einstein and Eddington” (two nerdy scientists for the price of one), and I am in geek heaven. Recently, I was thrilled by “The Imitation Game”—the story of Alan Turing and his quest to break Germany’s WWII secret code. While I would never dare to compare myself to Mr. Turing, I like to think that we would have a few things in common. One area would be our shared interest in natural language processing and intelligent behavior.

Way back in 1950, Turing crystallized his research into these studies in what has become known as The Turing Test. Simply put, The Turing Test is a test of a machine’s ability to impersonate a human being. For a machine to pass The Turing Test, it must be able to participate in a conversation with a human being to the point where the human doesn’t realize that he or she is interacting with a machine. I can only imagine what Turing would think of today’s technology such as Siri, Alexa, and Google Home. Better yet, imagine Alan conversing with the robot, Sophia. Would he be excited or frightened? Personally, I am a little of both.

Real or Not

If you have been reading my articles on No Jitter and here on the Avaya blog, you know how enamored I am of the Breeze and Zang workflow designers. Although I have spent the bulk of my professional life writing software in programming languages such C++ and Java, I have fallen in love with how quickly I can use the Breeze/Zang tools to go from idea, to prototype, to a production-quality application. I like to say that if you can draw it on a whiteboard, you can “code” it with Breeze.

So, the day I decided to build a text bot, I knew exactly how I was going to do it. Starting with a list of things I wanted my text bot to do, I was soon drawing out message flows and decision points (if this, do that). Once I was happy I had captured all the salient points, I turned to my computer and began typing. Early on, I realized that there was no way on earth I could capture all the different text messages my application would need to process. For instance, how many different ways can you ask for the location of a store? “Where are you located?” “What is your address?” “What city are you in?” “How can I find you?” The variations are nearly endless.

To solve this problem, I turned to natural language processing (NLP) and artificial intelligence (AI). That, of course, led me to the 500-pound gorilla in the room—IBM Watson. With Watson, I can build “Conversations” that allow me to create intents, entities, and dialogs. Intents are used to classify a request. You can think of entities as modifiers to those intents. Dialogs are the words you want to “speak” after determining the intent.

For example, consider the phrase “Are you open on Sunday?” Here, the intent could be classified as “hours.” The entity is “Sunday.” A proper dialog could be, “We are open on Sunday from 12:00 to 5:00.” To keep things simple, I created three intents for my bot: Directions, Holidays, Hours. Those intents resulted in three dialogs. I left off entities for now.

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My next decision point had to do with maintaining a conversation over many text messages. For that I choose Avaya’s Contest Store, which allows me to temporarily store information about a text conversation. This information can then be accessed over the life of the chat.

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Now that I had an engine to process incoming text messages (Watson), and a method of maintaining a chat’s context (Contest Store), it was time to launch the Avaya Breeze Engagement Designer. I will admit that I still had a few logic problems to work through, but I would not be stretching the truth if I said that I had a rough draft of my text bot up and running in less than an hour. Working through those remaining issues consumed another couple of hours, but in a fraction of the time it would take me to write my application in Java, my bot was accepting text messages, building contexts, and texting back replies.

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I should also say that my bot is fully multi-user. It didn’t matter if one or one hundred people were all texting in at the same time. My bot kept track of each individual conversation and no one received a text meant for someone else.

 
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While my example bot is fairly simple in terms of what it can handle, the framework is extendable to just about any SMS conversations you might want to support. Future plans have me using Context Store to save the entire conversation between human and machine. Not only could this be useful for determining how accurately my bot responds to incoming requests, but it could also be used to help better serve customers. A recorded chat sessions could be presented to a human agent in the case where the user moved from text to a phone call.

Next, I would love to incorporate some of the other features that Watson provides. For example, by detecting the tone/sentiment of the conversation, my bot could sense if the human was becoming frustrated with the answers he or she was receiving from my bot. This would allow the bot to either escalate the chat to a live agent, or have an agent follow up afterwards to help soothe over what might have been an unpleasant experience – or both.

Mischief Managed

Human to human conversations aren’t going away anytime soon, but more and more machines are going to step in to handle the easy to moderately hard stuff. The point is not to trick people into thinking they are talking to a human being. The point is that machines can handle tedious jobs without coming across as machines.

While I highly doubt that anyone will ever make a movie about Andrew and his fabulous text bots, it isn’t all about fame and glory, right? This is exciting technology and the fact that I can use Breeze to create sophisticated bots by easily combining powerful, but disparate technologies, is red-carpet stuff.