INDUSTRY NEWS
First RTS 22 Fine Since MiFID II Go-Live
Author:
Sophia Fulugunya
Director of Transaction Reporting
29 January 2025
The FCA has issued a £99,200 fine to a MiFID investment firm for failing to submit 46,053 transaction reports between October 1, 2022, and March 31, 2023. These reports, covering high-risk single-stock CFD transactions, were a regulatory requirement under Article 26(1) of MiFIR.
Key Takeaways:
• Accurate Reporting is Crucial : Transaction reports are fundamental for regulatory oversight, helping detect and prevent market abuse.
• Systems & Controls Matter : The firm’s failure highlighted weaknesses in its reporting framework, data validation, and oversight mechanisms. This highlights the need for firms to have robust governance, automated reconciliation, and regular reviews to catch reporting gaps before regulators do.
• Proactive Notification is Key : While the firm eventually identified the issue internally, it failed to self-report to the FCA. Instead, the regulator uncovered the breach independently, an aggravating factor that breached Article 15(2) of RTS 22. Timely disclosure could have led to a more favourable outcome.
• The FCA is Watching : The regulator is increasingly relying on real-time data analytics and cross-market surveillance to detect non-compliance. This fine serves as a clear warning: if a firm isn’t reporting accurately, the FCA will find out.
This case marks the first-ever enforcement action for transaction reporting failures under UK MiFIR, setting a precedent for future cases. With regulators globally tightening their stance on data quality and transparency, firms must act now to ensure compliance.
At Qomply, our MiFID 101 as well as Governance training sessions cover the above points and are designed to equip firms with the tools to ensure reporting aligns with regulator expectations.
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Qomply takes away the pain by getting transaction reporting right the first time.
Qomply’s technology automatically executes a sophisticated matrix of rules and scenarios across reports from field-level to business-logic level. With thousands of validation rules, Qomply easily exceeds the 250 validation rules set forth by the regulators.
Firms are empowered to conduct real-time checks as well as retrospective checks – making Quality Assurance, Remediation Exercises and Day-to-Day reporting straightforward.
Qomply’s easy-to-use dashboard empowers firms to send their reports directly to the regulator – bypassing costly fees with efficient, straight-through processing power.
This all leads to the fewest number of steps in the pipeline of reporting and ensuring reports are right the first time.
