MiFIR Transaction Reporting

Transaction Reporting is a highly complex area that many firms struggle to fully understand and successfully implement, as demonstrated over the years by a number of high profile enforcement cases. Transaction Reports are primarily used by the Regulator in the detection of Market Abuse and therefore it is important that reports are accurate and complete.

Fines for transaction reporting failures lead to reputational damage and potentially costly reviews in the form of s166 Skilled Persons reports. We have also seen many firms and their senior management being required to sign attestation letters issued by the FCA concerning the accuracy and completeness of their transaction reports.

MiFIR Trade Reporting

The purpose of MiFIR trade reporting is to promote transparency in trading venues and OTC markets and to support fair price discovery and liquidity through the timely provision of information to the market. Deferral of publication is permitted for certain instruments and transactions meeting particular criteria.

How Duff & Phelps Can Help

If you are facing regulatory action or require some independent and expert assurance that your current transaction reporting and/or trade reporting arrangements meet the required standards, Duff & Phelps can offer expert reviews and assurance to manage your potential regulatory risk. Our transaction reporting specialists have over 20 years’ experience of working in the FCA’s Markets Reporting Team (MRT) (formerly Transaction Monitoring Unit (TMU)), combined with extensive experience of working within financial firms and providing consulting services to investment banks, brokers, platform providers, asset managers, approved reporting mechanisms (ARMs), exchanges, multilateral trading facilities (MTFs) and organized trading facilities (OTFs).

Whether you are a smaller firm looking for a subject matter expert or a global institution looking for assistance with reporting your complex derivatives, our specialist staff can help you. We tailor our approach to the trading activities and processes of our clients.

Our services include:

• One off or annual assurance reviews

• Assisting firms and senior management when signing a transaction reporting attestation letter to the regulator

• Deep-dive reviews and regulatory investigations

• Preparing for visits from regulators in relation to transaction reporting

• Managing or assisting with transaction reporting remediation and back reporting programs

• Capturing and documenting the reporting requirements specific to your trading scenarios and product mapping across all systems

• Documentation (policies, operational procedures and reporting logic)

• Independent data accuracy testing of all instruments, scenarios and data fields

• Preparing and delivering technical, regulatory and operational staff training across departments