Michael Huertas is an English and Irish qualified Solicitor with Allen & Overy LLP’s Frankfurt office specialising in financial services regulatory and structured finance matters. His professional practice focuses on emerging regulatory issues in the Banking Union and CMU. His academic research interests cover cross-border issues in conduct of business regulatory reforms with a focus on collateral, custody and client asset/client money arrangements, offering proposals on how to identify, mitigate and manage what his research terms “conceptual translation risk” and the resulting costs. The usual disclaimer applies. The views expressed here are purely personal and need not reflect those of Allen & Overy LLP. The author would welcome dialogue on any of the issues raised herein or in relation to his research interests.