In this Market Watch , the FCA outlines its recent observations on the transaction reporting and instrument reference data regimes. With the objective to provide firms with information necessary to uphold and improve the quality of their transaction reports and financial instrument reference data submissions.
Please see below the validations Point Nine already has in place to resolve some of the issues identified by the regulator. Thereby ensuring the data quality of the transaction reports submitted on behalf of our clients is maintained at all times:
MIFIR Validations
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FCA Market Watch
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Point Nine Response
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- Unique national identifiers (inaccurate reporting)
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Checks regarding the pattern of every unique identifier as well as the priority specified in Annex II of the Commission Delegated Regulation (EU) 2017/590
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- Branch reporting, whether the investment firm is covered by directive 2014/65/EU (Field 5, RTS 22)
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Point Nine applies validations to verify Investment Firms status and entity type against the applicable FCA / ESMA entity registers
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Where applicable the reporting chain will be discussed during the onboarding process with the client and validations will be put in place, so that Venue field is correctly populated with either MIC of venue or XOFF
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Incorrect or missing instrument reference data
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Point Nine has validations to autocorrect the instrument full name field so that it contains a clear description of the financial instrument traded, for transactions executed in financial instruments that are not admitted to trading or traded on a trading venue (eg.CFDs)
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An instrument’s termination date is also validated against the underlying maturity / expiry date reported in the transaction report
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Point Nine applies a full CFI validation check (Pattern, Possible values and position, CFI attributes are validated against the relevant FIRDS register and also relevant data fields in the transaction report eg.Delivery, Option Type, Style, Asset Class / Type )
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Incorrect population of Executing entity identification code
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Executing entity identification code is pre-defined and validated before the submission
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Misuse of the aggregate client account
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This will be discussed during the onboarding process and validations will be put in place. The aggregate client account will not be used for any other purpose than set out in the applicable guidelines. The data is reviewed before go live so any possible issues can be identified
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