Are you in line with your MiFIR obligations?

Almost 4 weeks since MiFIR Transaction Reporting commenced!

It has been almost 4 weeks after the go live date of MiFIR transaction reporting obligation (i.e. the 3rd of January). As expected, not everything went smoothly on the first weeks of reporting. Many reporting entities were still struggling to collect necessary data like personal information and as a result they delayed to initiate the T+1 transaction reporting. At the same time various National Competent Authorities (NCAs) systems periodically experienced significant delays either in transaction reporting submissions acceptance, or in providing response feedback files. Some of these delays were caused by a significant backlog of file submissions.

ESMA, capturing the fact that a big number of investment firms have not collected LEIs from their legal entities counterparties to use on their transaction reports, has issued a statement just 2 weeks before the going live date, to support the smooth introduction of the LEI requirements. ESMA clarified that for a temporary 6-month period, investment firms may still trade with counterparties that haven’t yet obtained an LEI code, under the condition that they collect necessary documentation and immediately apply for the issuance of the LEI on behalf of their counterparty. Once the relevant LEIs have been obtained, the investment firm should submit its transaction report.

Despite the fact that the transition to MiFID II/MiFIR live transaction reporting implementation was not a perfectly smooth procedure, the obligation to comply from the 3rd of January 2018 onwards is of course unquestionable. MAP FinTech has already helped a significant number of reporting entities to start live reporting during the past few weeks and continues to support others on fulfilling their MiFIR transaction reporting obligation.

If you are an EEA entity or a Branch of a non EEA entity (an Investment firm, a Bank or a Portfolio Management company) that:

• Receives and transmits orders, or executes orders on behalf of clients

• Is dealing on own account or

• Is making investment decisions in accordance with a discretionary mandate given by your client

And you are executing transactions in either:

• financial instruments traded on an EEA trading venue or for which a request for admission to trading has been made or

• financial instruments where the underlying financial instrument is traded on an EEA trading venue or

• financial instruments where the underlying instrument is an index or a basket composed of financial instruments traded on an EEA trading venue

And have not been reporting up to date, you are definitely in breach of your MiFIR transaction reporting obligation.

MAP FinTech experts team can guide you through the obligation requirements and help you automate the reporting procedure to your NCA or a pertinent ARM.

Contact us if you would like to discuss how we can assist you to prepare for MiFIR transaction reporting obligation.