MiFID Transaction Reporting | Troubleshooting
20 June 2022
This article discusses the reasons that a transaction might be eligible for deferred post-trade MiFID reporting and common problems associated with it.
An important part of the MiFIR regulations concerns the prompt publication of post trade OTC Trade data to enable improved market transparency.
And to make the job of finding out if OTC post trade data is being correctly published, the NCAs can use information held within transaction report to identify possible errors.
With this in mind, it would be good for firms to check that they have been reporting OTC trades and transactions correctly.
For Investment Firms both in the same reporting regime (FCA or ESMA), in general for an off-venue OTC trade, the seller is responsible for trade reporting. The exception to this is if one of the counterparties is an SI, then the SI has reporting responsibilities.
The other reporting situation for dealing off-venue is when one of the counterparties is in a different reporting regime (or none). In this case the MiFID investment firm is responsible for trade reporting to their home regime.
Post Trade APA publication should happen in real time, but for some trades this publication can be deferred. The reasons for deferment are listed below. More than one flag maybe applicable.
There a few points to bear in mind when looking at the OTC Post Trade indicator. At Qomply, common problems we have seen are:
A large number of Investment Firms outsource the calculation of the OTC post trade indicator flag to their ARM. This is perfectly acceptable to the NCAs but it is worth remembering that outsourcing does not remove responsibility for correct reporting away from the Investment Firm. This is a further reason to get your MDP files from your NCA and set up a reconciliation programme.
Founded in 2019, Qomply is a RegTech company and our mission is to empower financial firms of all sizes to meet their regulatory transaction reporting requirements (MiFID, EMIR, SFTR, and ASIC) with best-in-class technology solutions that are easy to use at affordable price points. Our award-winning ReportAssure Platform, powered by our proprietary assurance engine, performs one of the most comprehensive arsenals of accuracy checks in the industry, giving customers peace of mind that their transaction reports are as complete and accurate as possible. And by offering affordable, modular subscriptions, we enable financial firms of all sizes to benefit from high-quality, regulatory reporting technology.
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