The TRADE 54 | Page 65

[ M I F I D Beyond best execution, pre- and post-trade transpar- ency represents a major component of MiFID II. With the introduction of approved publication arrange- ments (APAs) and approved reporting mechanisms (ARMs), a far greater volume of trade data will be reported and published. APAs will make data publicly available on both a pre- and post-trade basis, and the regulation will drive a significant increase in reporting in comparison to current requirements. The transparency rules are wide-ranging and complex, and it is incumbent upon firms to determine which trades must be reported and which party must fulfil the reporting obligation. When undertaking ac- tivity on a European venue, it is the venue that will be responsible for publication, whereas all other activity must be published via an APA. Firms will therefore need to fully understand the trade process to ensure the appropriate party reports the trade to a publication I I | F X ] venue. The regulation also formalises the transaction reporting require- ments, the principle purpose of which is to provide competent “It could be very tight to be live in time for January.” PETE EGGLESTON, FOUNDER AND DIRECTOR, BESTX authorities with the information needed to detect market abuse. Both trade reporting via APAs and transaction reporting via ARMs will pose major systems challeng- Issue 54 TheTradeNews.com 65