FCA Market Watch 72

In this edition of Market Watch 72, the FCA outlines their recent findings on the quality of service provided by Approved Publication Arrangements (APAs) and Approved Reporting Mechanisms (ARMs), collectively known as Data Reporting Services Providers (DRSPs). Investment Firms may use a DRSP to meet their MiFID II regulatory reporting obligations.

ARMs report details of transactions to the FCA on behalf of investment firms. APAs publish post-trade transparency reports on behalf of investment firms. Thus facilitating market transparency and enabling both the FCA and investors to get accurate and comprehensive trading data.

The FCA grouped their findings into 6 main topics:

• connectivity
• data quality
• fees
• unregulated services
• barriers to switching
• overall customer experience

In the context of these FCA findings, we explain how the Point Nine service can assist clients with their MiFID II regulatory reporting obligations and the submission of their transaction reports to their DRSP or NCA.

FCA Findings	Point Nine Benefits
Data Quality “With specific reference to ARMs, Article 11(1) of onshored RTS 13 requires ARMs to have arrangements to identify transaction reports that are incomplete or contain obvious errors caused by clients. As per the FCA’s transaction reporting webpage, ARMs are encouraged to implement other checks and validations beyond those set out in our validation rules where they have assessed this will improve the data quality of their submissions.”	The Point Nine Validation Engine contains many validation rules which go above and beyond the requirements set by the FCA or ESMA. Once our clients raw data is imported into our system it will initially undergo the bespoke validations set by our clients according to their business rules and requirements. Secondly are the many validations in place to meet the requirements set by the ARM or NCA. Thereby ensuring our clients transaction reports are successfully submitted to the ARM / NCA and the transaction data submitted is accurate and is of a high quality.
Barriers to switching “Surveyed clients consistently cited the cost of implementing a project to onboard with a new provider as the main barrier to switching DRSP. We also observed that client onboarding timeframes can vary significantly. Timeframes ranging from 48 hours to 4 months were cited. This is largely driven by differences in testing timelines depending on the complexity of client systems and expected reporting volumes.”	Here our clients can benefit from Point Nine’s many years of connectivity to the various ARMs and NCAs both in the UK and EU. The Point Nine service can provide our clients with a quick and seamless switch to another ARM or NCA if required.