MiFID II Handbook | Page 29

It is important for market participants to realise that MiFID reporting obligations extend beyond EU / EEA borders .

text ( the Methods and arrangements for reporting financial transactions ) and encompasses a raft of reconciliation and assurance requirements . Firms now become liable for identifying and correcting instances of over- and under-reporting , reconciliation of all reporting for timeliness , completeness and accuracy and for identifying errors and omissions in transaction reporting .

The industry faces external challenges in the timeline and complexity of transaction reporting . Mandating of ISIN identifiers for all products traded on trading venues and their equivalents is subject to much discussion and their creation , dissemination and accuracy will be key to meeting the completeness and accuracy demands of the regulation .
How the industry are responding
Brokers are in the process of assessing how they might support clients for MiFIR , with manydeciding they cannot support the provision of delegated reporting services , due to their unwillingness to support sensitive personal data in their reporting systems , and associated potential liabilities against entities and individuals .
On the traditional buy side , many firms have reached the conclusion that they will need to self-report under MiFIR , requiring the implementation of a reporting and control structure to support all MiFIR requirements . As part of the process of analysing self-reporting requirements , many firms are also reappraising delegated reporting processes for EMIR , not least because the cost benefits of delegated reporting have not been proven in

It is important for market participants to realise that MiFID reporting obligations extend beyond EU / EEA borders .

CHRIS DINGLEY , ABIDE FINANCIAL
application . In fact , monitoring compliance through multiple vendor GUIs and broker interfaces is proving to be complex and inefficient . It is also the case that while businesses struggle to keep up with the size and complexity of regulatory change , at this point in time delegated reporting providers can not all guarantee compliance .
Easing the burden The existing service model in the reporting industry clearly does not meet the transaction reporting needs of most firms in 2016 . The Trade Repository , Approved Reporting Mechanism or other mechanism accepts transaction reports but does little more than validate these for data field conformance .
Clients are increasingly demanding visibility of the full lifecycle , report delivery timeliness , reconciliation of reports from source systems and deployment of reporting hubs that actively support the decision making process . This is driving adoption of a new model in reporting provision where reporting delivery and assurance is delivered as a core component of the service model .
Full service transaction reporting providers can better support the demands of system integration , apply logic based rule sets , deliver reports to the end point , manage exceptions and provide the rigour of ongoing consultancy and advisory on evolving regulations to keep the reporting counterparty safe .
Many firms have chosen to partner with Abide Financial – a specialist provider focused exclusively on understanding and managing the impact of regulatory change on transaction reporting processes , and a reporting infrastructure that supports end-to-end reporting for multiple regulatory regimes and reporting destinations .
Specifically , Abide Financial ’ s PROXIMITY programme combines a systematic and guided approach to meeting regulatory reporting timelines with an established and efficient , end-to-end implementation , technology , operations and compliance ecosystem that helps all reporting parties manage the challenge of MiFID II / MiFIR , and other regulatory reporting obligations . l
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