On the 3rd of October 2022, the UK’s FCA issued Market Watch No 70 focusing on MiFIR transaction reporting issues. The FCA identified several areas of concern including:
- The proper reconciliation of trading records with data held by the regulator.
- Promptly notifying the FCA of an error or omission within a transaction report.
- In determining the meaning of ‘execution’, UK branches of third-country investment firms must consider additional criteria and not rely solely on the geographic location of a trader.
- Misuse of the ‘INTC’ reporting convention.
- Firms are reporting a market identifier code (MIC) when transmitting an order to an executing broker who then executes the transaction on a trading venue. The venue field should be populated ‘XOFF’ by investment firms that are in a chain and do not access the venue directly.
- In the case of transactions executed in financial instruments that are not admitted to trading or traded on a trading venue (e.g., CFDs), the instrument’s reported name should contain a clear description of the financial instrument traded (e.g., Vodafone CFD).
We at MAP Fintech, a pioneer in providing software as a service solutions, have created a platform that provides MiFIR (both EU and UK) obliged entities with a powerful automation tool that creates and submits timely, accurate, and complete transaction reports.
The Polaris Platform is geared towards firms with demanding reporting schedules that require a one-stop shop for their reporting needs. Moreover, the platform is supported by a dedicated support team that can help with technical (e.g., platform integration), as well as compliance queries. As such, we can assist firms to safely navigate the regulatory regime and avoid pitfalls such as the ones identified above by the FCA.
Finally, our team can perform in-depth health checks on your current reporting setup to identify any shortfalls and suggest the appropriate remediation measures to ensure ongoing compliance.
Contact our team of experts here.