What is it?
As part of MiFIR, Investment Firms should have arrangements in place to regularly reconcile their front office transactions against data samples provided by their National Competent Authority (NCA).
If your NCA does not have samples to provide, as an Investment Firm you should look to reconcile against files that your ARM or Trading Venue has submitted on your behalf, for example, the handback files from your ARM.
Why is it important?
MiFIR/UK MiFIR requires Investment Firms to:
- ensure their transaction reports are complete and accurate; and
- have arrangements and controls in place to monitor reports received by the NCA or sent by the ARM to the regulator.
Without accurate and complete transaction reports, the local NCAs are unable to monitor market abuse effectively.
What do you need to do?
If you are a MiFID Investment Firm, you should check with your local NCA on how you can get access to the transaction reports they hold for you. A firm should be able to request a sample where their LEI is identified as the ‘Executing Entity’ in the MiFIR Transaction Reports. If downloading from a portal is unavailable (for example in Cyprus through CySEC), you will need to request the reports, for reconciliation purposes, directly from the NCA.
In the UK, the FCA provides access to a Market Data Portal (MDP) where you can download files, up to one file a day, directly from the portal.
Once downloaded, the daily XML file can be used to compare against your internal trade systems to ensure all transactions that are in scope of the reporting requirements have been reported and reported correctly.
How can TRAction help you?
As a service provider, TRAction is not allowed to directly access the or any other NCA portal on an Investment Firm’s behalf. TRAction urges its clients to set up their own access and perform regular reconciliations of their in-house data against what is held with the NCA, as well as a reconciliation from in-house data against the ARM Confirmation files TRAction provides on a daily basis. If you are our client and require a detailed explanation of how to conduct a reconciliation, please feel free to request a guide from us or simply call us for a demo.
If there are any discrepancies or logic you are unsure of, TRAction is happy to help assist in investigating and providing explanations. Please contact us if any support is required.