Late Submissions

Late submissions of MiFID Reports to the regulator during Bank Holidays is one of the top, regularly occuring issues.

One of the most common issues arising out of conducting a MIFID Reconciliation and one that we see often at Qomply is late submissions of MiFID Reports to the regulator.

Many firms may falsely believe that their transaction reporting submissions have been running like clockwork for the past 5 years. Or, that late submissions are kept to a minimum due to daily monitoring. However, many firms fail to realise that their reports may not be submitted on time when key stakeholders are on leave. Staff holidays and Bank holidays are pivot times when “slippage” occurs in the monitoring of transactions or the trade processing framework that feeds into the transaction reports. This is typically due to the lack of availability of trained personnel to keep systems and controls properly running.

Things can go wrong in transaction reporting and the tight window of time (T+1) for submissions mean that there must be adequate monitoring of rejections and the knowledge as to how to resolve issues.

It is not always the fault of Operations or the regulatory reporting department. There could be a fault at any point along the pipeline used in producing reports. Issues may occur in the translation of the raw data into the report, a failure in static or reference data systems or in the knowledge required in resolving a rejected report. If staff resourcing is low due to a bank holiday or staff holidays, then the time to resolve an issue may exceed the report deadline.

One easy way to detect reoccurring issues in late submissions is to conduct a periodic reconciliation of the MDP file provided by the FCA or similar European regulators. If late submissions follow a pattern of staff absences, then steps can be taken to mitigate the risk such as training staff, ensuring support teams are available, and implementing adequate coverage during holidays.