MiFID II (the second Markets in Financial Instruments Directive) and MiFIR (the Markets in Financial Instruments Regulation) came into effect on 3 January 2018.
MiFID II and MiFIR together govern all aspects of the financial markets, including trading and reporting of financial instruments. Transaction reporting obligations are a large part of the regulatory regime and are contained in MiFIR. TRAction provides a full-service MiFIR solution that can simplify your transaction reporting requirements. Contact us if you would like to discuss your transaction reporting obligations.
The scope of MiFID II is broader than MiFID I transaction reporting which only applied to financial instruments admitted for trading on a regulated market (and to OTC derivative contracts and other financial instruments linked to those instruments).
MiFIR Reportability Assessment Tool
Are you unsure if you have MiFIR reporting obligations? TRAction has developed an assessment tool to help you determine your MiFIR reportability.
Transaction Reporting Obligations
As transaction reporting obligations are contained in the MiFIR regulation, there cannot be differing implementation between European nations. MiFIR imposes transaction reporting obligations in respect of specified transactions in financial instruments where the underlying instrument is traded on a European Economic Area (EEA) trading venue.
Which instruments are caught by the new regulations?
The scope of the MiFIR reporting regime includes:
- financial instruments admitted to trading or traded on an EEA trading venue or for which a request for admission to trading has been made;
- financial instruments where the underlying financial instrument is traded on a trading venue (ToTV) (guidelines state ‘underlying’ means immediate underlying instrument rather than ‘ultimate’ underlying instrument).
- financial instruments where the underlying instrument is an index or a basket composed of financial instruments traded on a trading venue.
What is a trading venue?
Under MiFID II/MiFIR, there are 3 categories of trading venue:
- Regulated Market
- Multilateral Trading Facility
- Organised Trading Facility
Do you know the difference? Find it out in our explanatory infographic designed for you!
Which entities need to report?
MiFIR transaction reporting obligations extend to:
- investment firms;
- investment managers providing advice and portfolio management to individuals;
- credit institutions;
- market operators;
- all financial counterparties under EMIR;
- central counterparties and persons with proprietary rights to benchmarks; and
- third-country firms providing investment services or activities within the EEA.
What information needs to be reported?
There are 65 reporting fields under MiFIR, including:
- Identification of the relevant parties – the legal entity, natural person or algorithm which submitted the order, made the investment decision or executed the order.
- Identifying information – a Legal Entity Identifier (LEI) for legal entities and personal identification information for natural persons.
- Product classification and identification – CFIs and ISINs for financial products.
Where should reports be made?
Firms can report directly to their National Competent Authority (NCA), or indirectly through an Approved Reporting Mechanism (ARM) or a third-party assisted reporting solution.
Delegated Reporting – How can we help you?
TRAction can provide you with delegated reporting solutions in accordance with the reporting requirements outlined above. We assist with understanding your MiFIR transaction reporting obligations and simplify your reporting process. If you want to find out more about our services, please contact us. Wondering about how much we charge? See our pricing schedules here.
Reporting Quality Checks
Our clients can also conduct regular check of our service quality. Visit our Regular Quality Checks page to find out how you can be assured that we are doing a great job for you.
Transitioning to new EMIR and MiFIR Reporting
Thinking of changing your current regulatory reporting service? Transitioning to a new regulatory reporting service can seem daunting. We understand the stress clients may face when switching to another TR, ARM or reporting delegate.
TRAction is here to make this process as easy as possible for you. We’ve worked extensively with other TRs and ARMs. Whether you are transitioning between TRs/ARMs or just looking to switch your reporting delegate, TRAction will ensure it is a smooth process and will help you manage the transition without hassle. Find out why you should make the transition to TRAction.
