19 January 2021
As of 1 January 2021, the European Securities & Markets authority (ESMA) and the FCA have been running two, separate FIRDS (Financial Instruments Reference Data System) databases.
The ESMA FIRDS database was intended to be the definitive reference for all financial instruments included in the scope of MiFID II. If an instrument or its underlying instrument is found in FIRDS for the trading date, then the instrument is deemed reportable. With Brexit, part of this responsibility of maintaining accurate data is with the FCA.
To facilitate the availability of data and enable firms to conduct quick reportability checks, Qomply, has released a free service that determines if a financial instrument is MiFID-reportable in the UK, the EU, or both.
Michelle Zak, co-founder of Qomply, comments “Qomply has offered a free service allowing firms to input an ISIN (instrument identifier), a string of ISINs, or upload a CSV file for a specific trade date. The service will report, as of that trade date, the region and reportability of that instrument. Therefore, firms will know, unequivocally, if the instrument was reportable, when, and where.“
This is the only service freely available that queries both EU and UK databases and conducts searches across multiple instruments at once. Qomply anticipates its service will remove the ambiguity of reporting obligations and allow firms to reach back in time to determine if an instrument was reportable in a specific region.
Zak notes “Understandably, any big changes have the potential to be disruptive, at least we can make it somewhat easier for firms to get answers on their reporting obligations in one place as opposed to issuing multiple queries across different locations”.
Qomply’s free service is available at https://qti.qomplypi.com/firdslookup
Article 26 of MiFIR created an obligation of Transaction Reporting that went into effect on January 3rd 2018. The legislature focuses on investment products that are traded on a traded venue (TOTV) or a derivative based on a product that is TOTV (also called UTOTV, underlying traded on a traded venue).
This key regulatory requirement, under the MiFID regime, plays a pivotal part in regulators detecting market abuse.
Please note the number of transaction reports received by the FCA is presented by trade date rather than by submission date.
Qomply is a leading regulatory technology firm offering a complete suite of regulatory tools that address the EU and UK regulation for transaction reporting, sensitive data and record-keeping.
Qomply’s flagship product, Transaction Report Diagnostic Health-Checker and Trade Reconciliation Suite, is a subscription-based, managed service that covers key aspects of the control framework for MiFIR transaction reporting including comprehensive checks for accuracy and completeness, trade reconciliation, over-reporting, and detailed reference data checks. Firms conduct their own periodic comprehensive checks on their transaction reports - both before and after submission to the regulator – putting them firmly in control.
For more information, please contact Michelle Zak, Director, on +44 (0) 7985 440464 or email@example.com
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