The European Market Infrastructure Regulation (‘EMIR’) & the Markets in Financial Instruments Regulation (‘MiFIR’) trade and transaction reporting rules allow reporting entities to delegate their reporting obligations to a third party.

Obligation to ensure the accuracy of the data

Where a counterparty decides to delegate the performance of such obligation to a third party, they are required to ensure the details of their transactions are reported correctly and accurately (Art 9(1) of EMIR & Art 26(7) of MiFIR). In other words, the delegating firm still retains full regulatory responsibility to ensure the accuracy and completeness of transaction reports submitted on their behalf.

How can TRAction help its clients meet these obligations?

TRAction has developed a simple system for our clients to review and determine whether TRAction is meeting its obligations as a third party reporting delegate.

On a daily basis, TRAction provides its clients with a ‘handback’ or confirmation file including the details of the transactions that have been uploaded to the Trade Repository (“TR”) or Approved Reporting Mechanism (“ARM”).

These handback files are generated upon successful completion of the transaction uploads to the TR or ARM and are returned daily to the secure portal.

If you would like to know more about the process developed by TRAction, feel free to contact us.

Emma Ladlow

Emma works in our Sydney office. At TRAction, she works on implementing changes to regulations, improving and expanding our regulatory reporting services and helping with new business initiatives. She has over 7 years’ experience in the finance industry with more than 5 years’ experience specialised in transaction reporting. She worked for one of the largest financial services organisations in the UK and then moved to Australia in November 2018 to join TRAction.