CySEC has recently carried out a review of compliance with MiFIR’s transaction reporting obligation and published its results in Circular 356.
This review’s purpose was to assess the completeness and accuracy of the transaction reports submitted by reporting entities to the Transaction Reporting Exchange Mechanism (TREM).
In its review, CySEC identified a number of data quality issues, which all reporting entities must take into consideration and, where necessary, take immediate corrective measures in order to remain compliant.
CySEC identified the following deficiencies, among others:
- Failing to submit the transactions to TREM within the required timeframe (T+1);
- Incorrectly populating field 48 (Index Name) with the name of other financial instruments instead of an index;
- Using the default trading time (field 28) instead of the actual execution time;
- Using a default price (price = 0) when reporting their transactions, and;
- Applying incorrect CFI codes (field 43).
CySEC also noted that many reporting entities are cancelling reports or submitting reports after T+1 without first notifying CySEC. In this respect, reporting entities are required to notify CySEC by completing and submitting the “Cancellations and Omissions Form” before proceeding with any of the below mentioned actions and await for CySEC’s response in order to proceed with the necessary corrective actions:
- The reporting entity will cancel erroneous reports and not resubmit them;
- The reporting entity will cancel erroneous reports and resubmit them;
- The reporting entity failed to submit reports in due time (T+1);
- A report was rejected and the reporting entity wishes to resubmit it after T+1, and;
- A transaction report was rejected and the reporting entity will not resubmit it.
CySEC will continue monitoring the aforementioned areas, as well as others such as rejected transactions, clients’ identifiers, etc.
How can MAP FinTech’s MiFIR Transaction Reporting Solution assist you?
MAP-MiFIR Transaction Reporting is a comprehensive solution with a high level of automation and extended field validation that is designed to assist firms comply with MiFIR’s transaction and trade reporting requirements.
MAP FinTech’s MiFIR Transaction Reporting solution also allows you to easily gather any relevant information to file the “Cancellations and Omissions Form” with CySEC and keep track of what needs to be reported following CySEC’s approval.
MAP-MiFIR Transaction Reporting solution allows clients to enjoy a cost-efficient, integrated solution delivered via a single platform, together with the rest of Polaris’ offerings and our team of experts’ impeccable support services.
Learn more about MAP FinTech’s MiFIR Transaction reporting solution here
About MAP FinTech
MAP FinTech is a leading and award-winning regulatory technology provider for the financial services industry, specialising in reporting solutions arising from the requirements of a number of complex and challenging international regulations such as EMIR, MiFID II/MiFIR, SFTR, FATCA and CRS. MAP FinTech also provides innovative and comprehensive solutions for Best Execution Monitoring, RTS 27/28 reporting, AI-Enabled AML Transaction Monitoring and Screening, Trade Surveillance (Market Abuse), and eKYC (Screening, eIDV, Document Authentication).