ASIC, EMIR and MiFIR trade and transaction reporting rules allow reporting entities to delegate their reporting obligations to a third party, they remain ultimately responsible for ensuring the details of their transactions are reported correctly and accurately under ASIC Reporting Rule 2.2.7, Art 9(1) of EMIR & Art 26(7) of MiFIR.

It’s important that you take all reasonable steps to ensure the completeness, accuracy and currency of the trade/transaction information reported.

How do you check the work quality of your delegate?

What you should do:

1. reconcile your raw data; and
2. cross check your invoice;
   
   

against the handback files or confirmations received from your delegated reporting provider.

Our recommendations:

1. confirm who within your organisation conducts this process; and
2. document this process on each occasion it is performed.
   
   

How does TRAction help its clients meet these obligations?

TRAction provides its clients with the handback files for review along with guidance to help reconcile the regulatory reporting done on your behalf against your raw data. This helps you ensure that TRAction is meeting its obligations as a reporting delegate.

On a daily basis, TRAction provides its clients with handback files which detail the transactions that have been uploaded the Trade Repository (TR) or Approved Reporting Mechanism (ARM). These files are generated every day upon successful completion of trade uploads to the TR or the ARM and are returned daily to the secure portal. The fields in the handback files are similar to those that were provided to TRAction for reporting purposes. We provide a detailed guide to assist clients with this process and our staff are available to answer any questions.