Confidentiality of information requirements Looking at inappropriate handling of information requirements issued by the FCA can hinder, or even compromise, our preliminary reviews of, and investigations into, suspected market abuse.
Legally privileged documentation Reminding market participants that material that could be subject to Legal Professional Privilege (LPP) should not be included in suspicious transaction and order reports ("STOR" reports) or market observations submitted to the FCA. If it is included, market participants risk losing or waiving any claimed legal privilege.
Transaction reporting Highlighting several data quality issues surrounding MiFIR transaction reporting (in addition to those highlighted in Market Watch 59 and 62), including:
Unreported Transactions, where firms have misinterpreted the reporting requirements or lack the infrastructure to report on a T+1 basis;
Clarification of the immediate underlying reporting requirement;
Inconsistent dissemination of trading venue transaction identification codes (TVTICs) by trading venues to investment firms;
Errors in the use of country of branch fields; and
Ongoing reconciliation between transaction reports and front office records to ensure reporting accuracy. The transaction report acceptance rate presented by the FCA should not be considered as a standard for assessing the completeness and accuracy of transaction reports.
SteelEye is a trusted compliance platform for MiFID II, EMIR, Dodd-Frank, MAR, SMCR & more. Established to reduce the complexity and cost of financial compliance, SteelEye enables firms globally to manage their regulatory obligations through a single platform.
SteelEye’s regulatory reporting suite for EMIR and MiFIR seamlessly consolidates, cleanses, validates and enriches all required client data in real-time and automates large parts of the transaction reporting process. By doing so, SteelEye addresses the significant data integrity challenge many firms have faced following recent regulations and enables them to improve their operational efficiency while freeing up resource.
Because of the complexities around regulatory reporting and the fact that firms can submit valid reports and still fall short of their obligations, SteelEye provides sophisticated validation tools, testing and reconciling all submitted reports against the reporting criteria, presenting any rejections for easy correction. Using the SteelEye dashboard, clients can thereafter manage, update and review the status of all submitted trades – feeling confident in their compliance.