TROUBLESHOOTING COMPLIANCE
ESMA has issued its fourth consultation package under the MiFIR Review, with a specific focus on amended RTS 22. This blog post by former FCA regulator, Sophia Fulugunya outlines the key proposals and dates.
TROUBLESHOOTING COMPLIANCE
Get instant results regarding the quality of your EMIR Refit transaction reporting data with Qomply’s free EMIR Refit Data Health Check. Take the pain out of your EMIR Refit reporting with a free data health check using Qomply’s award-winning Quality Assurance solution.
TROUBLESHOOTING COMPLIANCE
Qomply shares the top rejections for EMIR Refit in the UK. Unsurprisingly, many of these rejections are associated with lifecycle events. This is due to Trade Repositories (TRs) implementing stricter rules and constraints on lifecycle and event sequences, as required under ESMA guidelines.
TROUBLESHOOTING COMPLIANCE
Report Tracking Numbers (RTNs) are transaction-level identifiers disseminated to both counterparties—buyer and seller—by a trading venue.
One major concern is the timeliness of the availability and transmission of the RTN to counterparties with reporting obligations.
TROUBLESHOOTING COMPLIANCE
EMIR Refit went into effect in the EU on April 29, 2024. As the UK prepares for its launch later this year, industry experts Michelle Zak from Qomply, Lavinia Ponniah from The Depository Trust & Clearing Corporation (DTCC), and Alex McDonald from European Venues & Intermediaries Association (EVIA) came together to discuss lessons learned from the EU launch and share best practices.
TROUBLESHOOTING COMPLIANCE
Gain insights into regulator expectations for reconciling transaction reports with our latest guide, written by Qomply's Director of Transaction Reporting and former FCA regulator, Sophia Fulugunya. Guide contains essential insights into the requirements, best practices, and options for reconciling transaction reports.
TROUBLESHOOTING COMPLIANCE
Navigating compliance challenges linked to MiFID II's Aggregated Client Accounts (INTC) remains an ongoing concern for investment firms. Qomply’s latest article decodes the complexities of INTC compliance, emphasizing its importance, ESMA's proposed changes, and how Qomply can help.
TROUBLESHOOTING COMPLIANCE
Since we launched QomplyDirect in January 2023, we have seen tremendous interest from firms wishing to have more control in their regulatory reporting and costs. To this end, we have prepared Frequently Asked Questions to address the most common concerns.
TROUBLESHOOTING COMPLIANCE
Historical data from 2018 to 2020 suggests that over 50 percent of firms inaccurately reported their transactions. Discover Affordable MiFID Remediation Solutions with Qomply: Save up to 80% on costs through Direct Reporting or Exclusive ARM Discounts for Back-Reporting.
TROUBLESHOOTING COMPLIANCE
Qomply's Director of Transaction Reporting, Sophia Fulugunya discusses transaction reporting reconciliation. Sophia describes what constitutes a good reconciliation, the key components, how often firms should reconcile transactions.
TROUBLESHOOTING COMPLIANCE
Firms commonly ask what “good governance” should look like in terms of transaction reporting structure. In short, there is absolutely no one way of doing this.
Irrespective of the size of the firm, good governance starts at the top and “filters down” through a traceable line of discussion and actions.
TROUBLESHOOTING COMPLIANCE
In the FCA's MarketWatch 74, the regulators encourage firms to adopt market conventions when specifying Price and Quantity notations.
Consistency in reporting Price and Quantity enables the regulators to efficiently conduct regulatory supervision.
TROUBLESHOOTING COMPLIANCE
Whilst familiarity of multiple reporting regimes may be of benefit in understanding requirements, there are some distinct differences.
One difference lies in the recognition of the index TONA (TONAR, the Tokyo Overnight Average Rate).
TROUBLESHOOTING COMPLIANCE
Many regulatory reporting teams are cross-functional and may be involved in implementation of various regimes including MiFIR and EMIR.
This guide includes some of the most important differences to be aware of with EMIR Refit.
TROUBLESHOOTING COMPLIANCE
There are some distinct differences between seemingly similar fields and the expectations of the required data in MiFIR and EMIR Reporting
It is important to be mindful that transactions executed on third-country equivalent venues should be considered OTC as opposed to ETD.
TROUBLESHOOTING COMPLIANCE
There are some distinct differences between seemingly similar fields and the expectations of the required data in MiFIR and EMIR Reporting
For example, unlike MiFIR, in EMIR, FX Swaps should appear in one transaction report therefore removing the need to separate into two.
TROUBLESHOOTING COMPLIANCE
Qomply has developed a powerful stand-alone tool that simplifies the conversion process of the financial regulator MDP XML files into user-friendly CSV files.
This new tool removes the complexity of working with XML files and aids in data saving valuable time when users simply need to see the XML in Excel.
TROUBLESHOOTING COMPLIANCE
Whilst familiarity of multiple reporting regimes may be of benefit in understanding requirements, there are some distinct differences between regimes and the expectations of the required data.
For example, unlike MiFIR, Client Codes in EMIR should not contain any personal data.
TROUBLESHOOTING COMPLIANCE
There are things that can go wrong with Front Office systems that may go undetected. One common issue is duplicate trades.
Duplicated trades are easily detected by a repeated Transaction ID but what if your Front Office System or processes are creating a completely new ID for the same trade?
TROUBLESHOOTING COMPLIANCE
In an aim to improve data quality, the EMIR Refit transaction reporting regime introduces an increased number of fields, workflows, and reconcilable fields. Qomply outlines the top 5 immediate challenges for regulated firms.
TROUBLESHOOTING COMPLIANCE
The regulators are fully aware of the frequency in which you are conducting reconciliations.
Detecting discrepancies in data between your Front Office system and files sent to regulator ensures a higher-degree of data quality. It also contributes to fortifying the entire reporting chain.
TROUBLESHOOTING COMPLIANCE
Client static data is key in completing the Buyer and Seller fields effectively, as well as other fields in the transaction report. If the client data is not properly mapped to the correct, active, LEI, this may lead to compounded issues in market surveillance within your firm as well as with the regulators.
TROUBLESHOOTING COMPLIANCE
This guide lists the "quieter" issues appearing in transaction reports that have been accepted by regulators. Many times, it is not until the regulators contact the firm that they notice their reporting was faulty.
TROUBLESHOOTING COMPLIANCE
Transactions reported without the required trading time precision may affect downstream market oversight conducted by the regulators.
TROUBLESHOOTING COMPLIANCE
Periodic reconciliation of transaction reports is a MiFID Requirement yet there are still firms who are not regularly checking their reports.
TROUBLESHOOTING COMPLIANCE
There are instances where Front Office systems or process creates a unique Transaction ID for the same trade. For a number of reasons, these are difficult to detect however they can lead to serious issues in reporting if left unattended.
TROUBLESHOOTING COMPLIANCE
Late submissions of MiFID Transaction Reports to the regulator during Bank Holidays is one of the top, regularly occuring issues that can go undetected by senior management.
TROUBLESHOOTING MIFID
Qomply's Michelle Zak speaks to Judy Leung, from Kroll, Uwe Hillnhütter, from Tradeweb, and Alex Chow, from the Investment Association, about Transaction Reporting topics that are still causing issues in the industry.
TROUBLESHOOTING MIFID
Guest Contributor, Bovill Regulatory Consultants, discuss regulators' exepectations reporting allocations on a Block or Fill level in MiFID transaction reports - clarifying how to determine the correct level of reporting.
TROUBLESHOOTING MIFID
The data quality of the Trading Venue Transaction Identification Code (TVTIC) in MiFID transaction reports has been the recent subject of European regulators. In response, European Investment firms have honed-in on ensuring this field is accurately populated.
TROUBLESHOOTING MIFID
Highlighting the keypoints to consider when modelling internal allocations or block trades in MiFID Transaction Reports.
TROUBLESHOOTING MIFID
When reporting the Trading Date and Time for transactions associated to a Corporate Event, many firms are getting this wrong and simply reporting transaction execution times.
TROUBLESHOOTING MIFID
The country fields in MiFID II transaction reports are the cause of much confusion for market participants. This article covers some of the pitfalls and provides guidance in getting these fields right.
TROUBLESHOOTING MIFID
Struggling with the use of XXXX and XOFF in denoting OTC trades? Not sure about reportability and which indicator to use? Qomply's free tool helps simplify the process.
WEBINAR
BDO hosts Qomply at Webinar on 16 June 2021
Webinar discusses top 10 reason why transaction rejected by FCA along with Common booking issues. Qomply demonstrates the use of technology to resolve errors in transaction reporting.
TROUBLESHOOTING MIFID
According the FCA, nearly 60pct of rejected transactions are due to the instrument not being found in their database. The CON-412 rejection code continues to plague operations and compliance departments.
Learn how to use FREE tools to determine instrument reportability and avoid over reporting.
WEBINAR
Stephen Hanks - FCA
Dr. Kay Swinburne - KPMG
Damon Batten - Bovill
Panelists share insights into the particular challenges faced by financial firms and the overall response and agility of the financial industry.
Moderated by Michelle Zak from Qomply.
TROUBLESHOOTING MIFID
To enable firms to conduct quick MiFID reportability checks, Qomply, has released a free service that determines if a financial instrument is MiFID-reportable in the UK, the EU, or both.
WEBINAR
An informal webinar, hosted by Bovill, where various regulatory topics are discussed. Qomply demonstrates their technology for checking transaction reports for accuracy, completeness, and timeliness.
TROUBLESHOOTING MIFID
Part 2 of a discussion that takes an in-depth look at transaction reporting issues alongside resolution and remediation. CON-412 Error, Cancellations/Corrections and periodic accuracy checks are discussed.
TROUBLESHOOTING MIFID
Strong likelihood that your firm is not complying with the MiFID II requirement for periodic reconciliation of transaction reports sent to the FCA.
TROUBLESHOOTING MIFID
Reconciling and auditing transaction data is an instrumental part of the reguluations with few firms being compliant. Read more about this key component of the regulations.
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