August 29th, 2008: Toronto, Ontario: The Caribbean Regional Compliance Association (CRCA) is pleased to announce that the 5th annual Regional Compliance Conference will be held in Trinidad and Tobago - November 10TH to 11th with additional Communication Workshop and Basel II Training to follow on the 12th. A comprehensive, networking opportunity for professionals in the compliance, regulatory, and anti-money laundering sectors of the financial services industry, the 5 th Annual CRCA Conference is anticipated to break attendance records from previous years with a full international line up of speakers, sponsors and delegates. This year the CRCA has secured Richard Berkhout of the Financial Action Task Force (FATF) for the Key Note Address. “Once again we have managed to secure top speakers for a wide range of topics and have aimed at addressing the needs and wants of delegates” reported Carolyn Hanson, Chair of the 2008 CRCA Conference Planning Committee, “Having the FATF present at this conference speaks to the tremendous work and effort that the Caribbean has shown in setting up extensive AML/ATF frameworks in the region and the exceptional profile of this conference”. The theme “Confidence in Compliance. The Corporate Advantage in a Changing Market” captures a mix of specialized compliance and AML subjects and includes such topics as Benefits of Adopting Central Compliance, Emerging Threats for the Caribbean Jurisdictions, Islamic Banking and High Risk Individuals. This year the conference has added two more optional workshops as well as the opportunity for delegates to receive CAMS certification with a CAMS® Examination Preparation Seminar and Examination. Diane Carrington of Positiveworks will lead an in depth Communications Workshop designed to support the compliance professional in managing the increasing volume of information required for their position with skill training in Mind Mapping, Speed Reading, Leadership Skills, Creative Management and Time Management. Also being offered is the Basel II Training Seminar that will provide delegates with comprehensive knowledge and skills necessary to understand the directive and support Basel II implementation. Sponsored and delivered by Intelligence Secured, this workshop will run from the 12th to 14th. CRCA member jurisdictions include Anguilla, Bahamas, Barbados, Bermuda, British Virgin Islands (BVI), Cayman Islands along with local compliance representatives from Trinidad & Tobago. Sponsorship sales have been very strong and the sponsors committed to date include: CLICO, World-Check, Butterfield Bank, World Compliance, Cayman Free Press (The Journal), Association of Certified Anti-Money Laundering Specialists® (ACAMS®), Amicorp BPO, FIBA, Fortent, Microgen Information Management, Intelligence Secured, RBTT Financial Group.

ISO27001/2 SECURITY TRAINING AND AWARENESS The ISO 27001 (formally BS 7799 and ISO 17799) is the recognised international standard for an Information Security Management System (ISMS). Building upon over ten years of development, it is now the International reference point for developing organisational systems security all around the world. Many organisations in both Private and Public Sectors of Commerce and Industry now recognise that information is their greatest asset. As any Director or Senior Executive will be aware, the success of any Business Mission is based on supply of accurate and timely information, and continuity of the IT infrastructure and assets. More organisations are now also becoming aware of the importance of Information Security to their technological critical business functions. This is much more than information technology (IT) issues, as it also encompasses the following areas: • Governance • Risk Management • Human Resources • Physical Security • Business Continuity • Regulatory and Legal Compliance By adopting a Security Framework based on the ISO27001, and ISO27002, organisations can demonstrate to their clients, and customers, their adoption, and deployment of tangible security systems, that will not only reduce the overall risk of insecurity, but will also underpin the business with security value add enabler. ISO27001/2 In-House Training: The Training Course will provide awareness, and training, and lead to supporting the required set of competences to develop, and deliver a ISO27001/2 Security Framework into the business, along with the associated core skills to accommodate the business requirements of the Digital Age. Trainer: Our Trainer Consultant is a Professor of Science & Technology, and is an expert in the field of BS7799, ISO17799, and ISO27001/2 with over 20 years experience in the arena of Information Security. He was also a contributor into the ISO17799, and ISO27001, and was the longest serving Chair at the Department of Trade and Industries (DTI) ISO17799/ISO27001 UK User Group for three years. Training Approach: The approach will provide an in-depth multi-level view to accommodate the correct level of joined-up awareness, with focused engagement of the ISO27001/2, including the following categories of the business: • Executive Overview • User Education • Technologist Support Awareness • Baselines Standards Requirements • Documentation For more information contact: r.fenwick@intelligence-secured.com

After the passage of the European Union’s 8th Company Law Directive on Statutory Audit (Directive 2006/43/EC), European and non-European companies listed in any country of the EU/EEA have to comply with the 8th Company Law Directive. EU/EEA Member States must comply with this Directive before 29 June 2008. In preparation, we would like to invite interested persons to review our E-SOX brochure in .PDF format for full course details which also include registration instructions.

Following the overwhelming success of our training events conducted in Iceland we are pleased to announce that we are organising and hosting Iceland’s first ever “Compliance & IT Conference & Exhibition” for professionals within Financial Services, Insurance, Legal & Information Technology sectors. Compliance is continuing to grow and become more central, as organisations need to reassure regulators that they are aware of, and responding to, frequent regulatory change. Responsibility for significant regulatory decisions will move to more senior levels, challenging firms' compliance, risk management, internal audit, legal and information technology functions as they provide the necessary support to comply with EU/EEA directives and avoid regulatory scrutiny. The aim of our conference is not only to deliver practical up to date information & expert advice and guidance from a number of industry experts, it is also to increase awareness and promote Iceland as a competitive jurisdiction within the EU/EEA which has a strong regulatory framework and has good risk management and corporate governance initiatives. Our conference will attract not only delegates from within Iceland it will also bring with it an international audience from within Europe & the US thus increasing Iceland’s visibility to potential foreign investors. In addition to the above, attendees will have access to leading authorities on a number of topics, be given information on latest trends and upcoming initiatives for 2008, be able to listen to an insightful discussion panel, form new relationships and have opportunities to review exhibitors products and, network with potential clients and colleagues. Full information on this event will be displayed on our website shortly, which will include full programme description, registration instructions and sponsorship opportunities.

MiFID, the European investment banking regulation, came into force on Nov 1 and banks will be hoping their preparation for the big day has paid off. MiFID (the Markets in Financial Instruments Directive) is Europe's attempt to make financial trading easier and fairer across the continent's borders. It was originally intended to launch in April 2006 but was put back by the European Commission to 1 November this year to give businesses a better chance of complying. Investment organisations have had to change processes and systems to comply with the stricter reporting and trading requirements of the new regulations. Companies now need to prove best execution on deals, taking into account issues such as cost, price, speed and venue. This side of MiFID is expected to prompt greater use of algorithmic and automated trading systems, which can quickly work out the best trading venues and provide a clear audit trail. Companies will also have to publish more information on trades than they have done previously, which means new comms infrastructures must be put in place. The Financial Services Authority (FSA) has said the UK industry is well prepared for the new regulations. But there have been suggestions some organisations may have issues with the record-keeping side. The FSA estimates that around 12,000 firms in the UK will be affected by MiFID. There have been questions raised about the extent to which smaller domestic players - which are also required to adopt MiFID - will benefit from it. In the run up to today's deadline, there has been much debate about what the exact requirements of MiFID are but analysts agree as long as banks are showing they are working towards compliance, the FSA will work with them to finish the job. But persistent failure to address MiFID could lead to private and public warnings from the FSA, fines and - in the worst case scenario - closure of the firm. Analysts feel non-compliance could also have a commercial impact as customers may choose to go with organisations that are fully MiFID-compliant, rather than those that have been found to be less so.

The U.K. Financial Services Authority has moved the implementation date for its new transaction reporting scheme under the Markets in Financial Instruments Directive to Nov. 5 from Nov. 1. Approved Reporting Mechanisms (ARMs) will replace Permitted Reporting Systems under MiFID. ARMs are transaction reporting systems to be used by firms that comply with Article 12 of MiFID and have to be approved by the FSA. The change is being made as a weekend changeover to the new system will significantly reduce the implementation risks associated with the transition to the new reporting regime for both firms and their Approved Reporting Mechanisms, according to the FSA's Market Watch newsletter. Firms should continue providing transaction reporting in the current format up to and including Nov. 2.

European Union states should speed up the adoption of sweeping new EU share trading rules to deepen financial integration and lift economic growth, the International Monetary Fund says. Fewer than half of the EU's 27 members have so far introduced the Markets in Financial Instruments Directive or MiFID into their national laws even though it comes into effect on Nov. 1. MiFID forms the cornerstone of the EU's single financial market aimed at offering people cheaper and a wider choice of investments by tearing down national barriers to cross-border competition. The IMF said in a report released on Tuesday that financial integration is one of the most promising avenues for boosting Europe's productivity and growth. "Accordingly, they (IMF directors) emphasised the need for a prompt implementation of the Markets in Financial Instruments Directive," the report said. EU Internal Market Commissioner Charlie McCreevy has already launched legal action against 24 states for being slow in implementing MiFID, thereby failing to give investment firms enough time to make costly and complex systems changes to comply with the new rules by November. The IMF said the key challenge was to ensure that national watchdogs implement the new rules uniformly. The global finance body said about half of the 13-nation euro area's 1 percent annual productivity gap with the United States was due to less advanced financial integration.

With just over three months left before the Markets in Financial Instruments Directive (MiFID) comes into force, just eight of the 27 EU member states have implemented the directive into national law. The directive has been introduced into domestic law by the UK, Romania, Ireland, Belgium, Germany, Denmark, France and Luxembourg, according to the European Commission (EC). EU states were legally bound to introduce MiFID into national law by the end of January to give market participante time to prepare their systems and organisations ahead of the 1st November start date. But the EC's Web site shows that the Czech Republic, Estonia, Finland, Hungary and the Netherlands will not implement MiFID until November. Greece and Spain will be even later in adopting the directive. Norway, Liechtenstein and Iceland, which are not members of the EU, will have complied with MiFID in October. Earlier this year EU internal market commissioner Charlie McCreevy threatened infringement proceedings against member states that are slow to implement MiFID. In March McCreevy wrote to the Ministers of Finance concerned expressing "deep concern" and warning that the delays could endanger the proper functioning of MiFID for cross-border servicing. This raises the risk that member states could face legal action by private parties who might claim damages for losses incurred because of late implementation of national legislation, said McCreevy.

Due to the overwhelming success of our MiFID, 3 Day Training event held in Reykjavik, Iceland in June, The Icelandic Business Magazine wrote an article on our MiFID event. The full article can be downloaded by copying this link into your browser http://www.intelligence-secured.com/files/MiFID_Article.pdf

LONDON (Thomson Financial) - London Stock Exchange Group PLC (LSE) has confirmed that it is in merger talks with Borsa Italiana SpA, the owner of Milan's stock exchange. Following recent press speculation, LSE said it is in discussions with the Italian group in order to establish whether a merger of the two businesses can be agreed. A spokesman for the group declined to provide further details, but confirmed that LSE will make a further announcement as appropriate. Speculation today also pointed to NYSE-Euronext making a merger offer for Borsa Italiana, but both groups declined to comment. Last year, the Italian group held talks for a tie-up with Euronext and Deutsche Boerse but no deal was agreed. Borsa Italiana and the NYSE-Euronext jointly control the MTS bond trading platform after Borsa Italiana and Euronext together bought 51 pct of MTS in 2005. However, the merger of NYSE with Euronext triggers scope for Borsa Italiana to buy out its partner's stake under a change of ownership clause in their MTS deal. Reports have said Borsa Italiana favours exercising its call option on the MTS stake but has not taken a formal decision on this. Borsa Italiana is seen threatened by competitive bank trading platforms, which can operate from November under the EU's MIFID directive liberalisation. Industry observers say Borsa Italiana is partly protected by its low trading costs, while efforts to diversify, including in energy products, will be another positive factor.

The MiFID (Markets in Financial Instruments Directive) directive, that will come into force on 1st November 2007, defines a series of new regulatory fulfilments for the redesigning of rules applicable to European financial markets and their operators. Borsa Italiana and BIt Systems have developed a series of MiFID-compliant services and, at the same time, have made available, within the site www.borsaitaliana.it, documentation and information relating to the new directive with the aim of helping current and potential clients to conform with the new obligations and requirements that the MiFID imposes. The MiFID-compliant services, that can be customised on the basis of specific requirements, allow banks, investment firms and Multilateral Trading Facilities (MTF) to fulfil the instructions of the new provision. - Post-Trade Transparency The MiFID states that regulated markets, MTFs and investment firms that carry out over-the-counter transactions must publish information concerning transactions on shares admitted to trading on regulated markets in real time, making them accessible to all investors. Gruppo Borsa Italiana will continue to provide the off-market disclosure service already available for shares traded on Borsa Italiana markets and will also make it possible to fulfil post-trade transparency obligations for all shares traded on European regulated markets. This information will be circulated to information providers and investors in real time through the new versions of Borsa Italiana’s information services. - Transaction Reporting With the introduction of the MiFID, investment firms will have to notify the relevant Authority, within the following working day, at the very latest, the details of transactions concerning all the financial instruments admitted to trading on a European regulated market. This obligation applies both to operations carried out in a regulated market and to over-the-counter operations. Gruppo Borsa Italiana will provide a new transaction reporting service that will allow intermediaries to fulfil this obligation with regard to all trades on financial instruments admitted to trading on European regulated markets. - Best Execution The MiFID introduces a best execution regime that is more complex than the current one. In particular, investment firms are required to adopt all possible measures to obtain the best possible result for the client, taking into account factors such as price, costs, speed and execution probability, the nature and the size of the order. In addition to this, investment companies must establish a precise order execution policy and must be able, when requested, to demonstrate to their clients that their operations comply with the execution policy. Gruppo Borsa Italiana will offer investment firms a series of services in support of activities to define, review and monitor the execution policy adopted by the broker himself. - Online Information Contents In addition to developing new services, a specific section dedicated to the MiFID has been created within Borsa Italian’s web site: www.borsaitaliana.it/speciali/mifid/homepage.htm Not only does this section highlight the main features and qualities of the markets organised and managed by Borsa Italiana, but its aim is also to offer a preferential access point to the MiFID topic. Texts of the main provisions and main consultation documents (e.g.: of the CESR, the European Commission, etc.) relating to the implementation phases of the new directive in the individual Member States can be obtained in this part of the site. In the MiFID section it is also possible to consultant all Borsa Italiana documentation, produced both for the purpose of financial education and in response to the various public consultations on the individual topics covered by the MiFID.

OMX has introduced a MiFID Service Menu designed to meet new opportunities and needs for market participants and investors on the Nordic Exchange as well as new or existing marketplaces. The Markets in Financial Instruments Directive (MiFID) will take effect in the EU region on 1 November 2007. The directive aims to promote further harmonisation of the EU capital markets. OMX has developed the Service Menu to meet MiFID opportunities and needs from banks, brokers, investors, regulators, exchanges and alternative marketplaces. The menu addresses three central needs: Assuring best execution for Nordic and Baltic securities Meeting MiFID transparency requirements Creating a MiFID compliant marketplace "As a market operator and technology partner, OMX leverages its expertise in the exchange industry to deliver value through continuous innovation and improved efficiency of financial markets. We understand first-hand how marketplaces work, in different regulatory environments, and the complex technology infrastructures that power them. Our track record includes integration of the Nordic Exchange as well as over 60 technology customers in more than 50 countries," says Jukka Ruuska, President of Nordic Marketplaces at OMX. The Service Menu provides a framework for all services targeted at helping customers meet MiFID requirements and gain new competitive advantage. OMX has already taken a number of initiatives that are part of the MiFID Service Menu. The recently introduced Proximity Service helps assure best execution for Nordic and Baltic securities by providing low latency network access to trading and market data. Earlier this year OMX initiated an in depth consultation among members on microstructure improvements. New tools and reports will also be introduced to facilitate best execution policy audits. Within the transparency requirements area, OMX has already reduced the fees related to cash equity trades and will be extending the trade reporting services to all EU securities. OMX will also introduce new services for systematic internalizers as well as new transaction reporting services. To help customers create MiFID compliant marketplaces, OMX provides business operations services, covering all aspects from administration and market operations to market surveillance, and outsourced back-office operations for market participants.

Today's announcement marks the culmination of CESR's Level 3 work programme in relation to MiFID (the full level 3 work programme can be accessed via the Web site: A key element in the successful application of MiFID will depend upon an intensification of supervisory convergence between its Members. CESR is publishing today its final MiFID Level 3 guidance and recommendation in relation to inducements, best execution, passporting and transaction reporting. These documents focus on the operational aspects that arise as a consequence of the provisions of the Directive and its implementing measures, and on identifying practical solutions to address the regulatory challenges to ensure certainty amongst market participants. CESR adopts recommendations on Passporting and a Protocol on Notifications (Ref. CESR/07-337 and Ref. CESR/07-317) CESR is today issuing to its Members, recommendations on passporting and a protocol on notifications, with the aim of fostering supervisory convergence and consistent implementation in the day-to-day application of the Passporting provisions under MiFID. Passporting of intermediaries was identified as one of the key priorities in CESR's MiFID Level 3 work programme. The passporting recommendations set out a number of practical proposals with the aim of promoting a common supervisory approach to Article 31 and Article 32 of the MiFID in order to guarantee efficient and consistent supervision of firm's cross-border activities. The paper contains 20 recommendations which set out: A harmonised approach and a common interpretation to the notification procedures set out in Article 31(3) and Article 32(6) of MiFID; A commitment to further work to develop a common model of practical cooperation regarding the supervision of branches; Clarifications on aspects regarding the supervision of tied agents, MTFs and representative offices; Transitional arrangements for the transition from the ISD to the MiFID passport. The Protocol on notifications provides a framework for cooperation between Competent Authorities with regard to the passport notification process for investment firms and market operators operating an MTF in the EEA under Article 31 and Article 32 of the MiFID. The substance of the Protocol details, both in relation to the 'freedom to provide services and activities' (Art 31) and the 'establishment of a branch' (Art 32): The content and nature of the information to be provided by the Home to the Host Competent Authority in the initial notification; The means of transmitting the notification; The timelines for transmission ; The addressee of the notification; The determination of who is responsible for guaranteeing its safe receipt; and The practicalities of dealing with notifications of changes to the information provided in the initial notification. During the course of consultation, CESR has considered the views of market participants and consumer representatives and has taken them into account both in developing and finalising the passporting recommendations. CESR also publishes a Feedback Statement (Ref: CESR/ 07-318) which sets out how the issues raised during consultation have been considered and reflected in the final recommendations. CESR adopts Q&A on best execution (Ref: CESR/07-320) CESR is today issuing a Q&A with the aim of fostering supervisory convergence and consistent implementation in the day-to-day application of the MiFID Level 1 and the MiFID Level 2 Directive requirements on Best Execution. MiFID's best execution requirements establish a new overarching standard that requires firms to implement a process that will enable them to obtain the best possible result for their clients orders on a consistent basis. This process-driven approach aims to promote two of CESR's most important objectives, namely market efficiency and investor protection by fostering competition between trading venues whilst at the same time promoting investor confidence by ensuring that investment firms will take all reasonable steps to execute their orders for the best possible result, by choosing the execution venue that appears most likely to do so. The best execution Q&A sets out to achieve a common supervisory approach in relation to the best execution requirements. It covers in a practical manner the content of execution arrangements, the content and degree of differentiation of the best execution policy, the possibility of using single execution venues, the assessment of the relative importance of the best execution factors, the notion of total consideration and fees and commissions, disclosure of information, consent, and the requirements of monitoring and review. During the course of consultation, CESR has considered the views of market participants and consumer representatives and has taken them into account both in developing and finalising the Q&A. CESR is publishing a Feedback Statement (Ref: CESR/07-321), which sets out how the issues raised by stakeholders during consultation have been considered and reflected within the answers contained in this Q&A. CESR adopts recommendations on inducements (Ref: CESR/07-228b) CESR is today issuing recommendations with the aim of fostering supervisory convergence and consistent implementation in the day-to-day application of Article 26 of the MiFID Level 2 Directive. Article 26 of the MiFID Level 2 Directive, entitled "Inducements", sets out requirements in relation to the receipt or payment by an investment firm of a fee, commission or non-monetary benefit that could place the firm in a situation where it would not be acting in compliance with the principle in MiFID Article 19(1) that the firm act honestly, fairly and professionally in accordance with the best interest of its clients. The document contains six recommendations and a number of supporting examples which illustrate some of the variety of situations in which Article 26 of the MiFID Level 2 Directive is relevant. The recommendations themselves clarify the range of application of the regime, specifying a common approach to the understanding of the different categories of payments within Article 26. The paper also introduces some indicative factors aimed at helping supervisors establish whether specific third-party payments are likely to meet the regulatory tests within Article 26(b). The paper further clarifies the effect of Recital 39 in interpreting the operative provisions Article 26. Finally, some direction is provided with regard to the possibility for firms to have recourse to summary disclosure in connection with third party payments. The content of these recommendations reflect comments received from industry and consumer groups during the course of two consultations. CESR has adjusted some of its views in response to significant issues raised by stakeholders both as a result of the two public consultations on inducements and the two open hearings. CESR also publishes a Feedback Statement (Ref: CESR/07- 316) which sets out how the issues raised during consultation have been considered and reflected in the final recommendations. CESR adopts guidelines on transaction reporting (Ref: CESR/07-301) Finally, CESR is also issuing today guidelines on MiFID transaction reporting. The transaction reporting regime established by MiFID is key for CESR members to monitor the activities of investment firms and to ensure that they act honestly, fairly and professionally and in a manner which promotes the integrity of the market. The reports can be made either by the investment firm itself; a third party acting on its behalf; by a trade matching or reporting system approved by the competent authority; by the regulated market; or, MTF through whose systems the transaction was completed. CESR members shall further exchange the reports between themselves through the Transaction Reporting Exchange Mechanism (TREM). This system for exchanging the data between CESR members is currently being developed by CESR. In addition to the technical work, some issues have been identified where there is a need for a harmonised approach by CESR members. The document published today provides guidance to three aspects of transaction reporting: practical solutions for the reporting obligations for branches; clarification as to what constitutes "execution of a transaction" for transaction reporting purposes; operational solutions for some aspects of reporting channels. During the course of the consultation process, CESR has considered the views of market participants and has taken into account the views expressed in finalising these guidelines. CESR also publishes a Feedback Statement (Ref. CESR/07-319) which sets out how issues raised during the consultation process have been considered and reflected in the final guidelines.

Yesterday, the Financial Services Authority (FSA) confirmed that its application of the European Union's MiFID rules in its supervision of outsourcing by firms will be based on the interpretation and guidance of the MiFID Connect group. This is the first guidance developed by industry which the FSA has recognised since publishing its Discussion Paper, FSA confirmation of Industry Guidance, last year, and the first formal Industry Guidance related to MiFID. The MiFID Connect guidance covers the 'common platform' FSA firms - those subject to MiFID and/or the Capital Requirements Directive (Basel II). The FSA collaborated with MiFID Connect on its outsourcing guidance which is intended to strike a balance between legal interpretation and practical examples. Michael Folger, FSA Director of Wholesale and Prudential Policy, said: "We think it right to proactively confirm this MiFID Connect guidance now ahead of our formal response later this year to the comments we have received on the industry guidance Discussion Paper. It will help common platform firms ensure their existing outsourcing arrangements will meet the FSA's new requirements from 1 November 2007, when MiFID comes into effect. Firms need to start checking their approach now as MiFID does not exempt existing outsourcing arrangements." MiFID Connect is a collaboration of 11 trade associations to advise their members in implementing MiFID. Members are The Association of British Insurers (ABI), The Association of Private Client Investment Managers and Stockbrokers (APCIMS), Association of Foreign Banks (AFB), The Bond Market Association, the British Bankers' Association (BBA), Building Societies Association (BSA), the Futures and Options Association (FOA), The International Capital Market Association (ICMA), Investment Management Association (IMA), The International Swaps and Derivatives Association (ISDA) and the London Investment Banking Association (LIBA). This confirmation is in line with the FSA's thinking on principles-based regulation. Last year, when releasing the above-mentioned discussion paper, FSA General Counsel Andrew Whittaker said: "These proposals will contribute towards more principles-based regulation by allowing us to focus on the main principles to be achieved, rather than the detail of how to comply with them. They will give firms guidance on ways of complying with FSA principles and rules, but in a way that should stimulate flexibility and innovation in meeting higher level standards."

On Tuesday the EU commission started to take legal proceedings against 24 EU member states on the grounds that those states failed to enact MiFID according to the set EU states could face rebuke for implementation delay of MiFID. So far only Great Britain, Ireland and Romania announced the complete implementation of the directive. The directive will come into force on 1st November 2007 and the deadline for legal implementation already expired on 1st January. EU internal market commissioner Charlie McCreevy has recently sent a letter to the finance ministers of the defaulting states, in which he expressed his great concern and required that MiFID should be on the top of their political agenda. In a press release issued on Tuesday McCreevy further reminded that more delays could harm the competitivity of banks and European securities firms. On the other hand McCreevy confirmed that most of the states committed to implement MiFID in May, June or July.