Qomply News

The requirement to publish a Post-Trade Transparency report is a well-defined aspect of MiFIR applying to financial instruments traded on a trading venue. Even if an instrument is traded bilaterally, the instrument may still be subject to post-trade reporting if it shares the same reference data details (Instrument Identification Code) as the dervatives traded on a trading venue.

Whilst Transaction Reporting accuracy and quality assurance has predominantly taken centre stage, with the recent ESMA publication of the Post-Trade Transparency “Guide” in July 2023, it is evident that regulators have an expectation that investment firms will perform periodic checks on their published post-trade data as well as their transaction reports.

The tricker aspect of post-trade reporting is that the report must be available as close to real time as possible, or more specifically, within 5 minutes of the trade. Whilst there are no permanent waivers for post-trading, there are a number of deferrals which can apply that will delay the broadcasting of the post-trade report to end of day, 48 hours, or even an extended period of up to 4 weeks. In rare cases, the post-trade report can be deferred for months.

Sophia Fulugunya, Director of Transaction Reporting at Qomply, says, "The obligation to ensure the accuracy of the published trade data sits with the investment firm even where they have delegated the reporting to a third party. It is not sufficient to completely rely on a third party to monitor the accuracy of your data and the firm itself is expected to take proactive steps to ensure that it’s meeting is obligations under MiFIR."

Qomply has introduced its new Post-Trade module that will automatically conduct extensive quality assurance checks on data published by APAs on behalf of investment firms. This forms part of the due diligence performed by investment firms and expected by the regulators.

“With the additional guidance from ESMA and the FCA forming a new post-trade reporting team, it is fair to say that there will be more proactive supervision of the regime similar to RTS 22 transaction reporting. As such, firms should endeavour to tighten up their reporting in preparations for increased regulator attention in this area", continues Fulugunya.

“Qomply's technology simplifies the regulatory guidelines making it easy for firms to conduct their due diligence in ensuring trading venues, APAs, and their counterparts are producing accurate post-trade reports", continues Fulugunya.

To discover more about Qomply's Post-Trade Diagnostic solution click here.