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Global Trustee and Fiduciary Services News and Views | MiFID II Special Edition 2016
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Transaction/trade reporting
MiFID II/MiFIR requires the reporting of both
trades and transactions. By January 2018,
MiFID II/MiFIR will have imposed a number of
alterations to the previous rules of reporting:
i) MiFID II trade reporting (near-real-time) that
will require firms to report via an Approved
Publication Arrangement (APA). These
reports are near-real-time broadcasts of trade
data for price formation and operation of best
execution obligations. These are reported via
trade reporting venues from where they are
disseminated to the market; and
ii) MiFIR Transaction Reporting (T+1). The
Approved Reporting Mechanism (ARM) regime
will remain in place. However, there are a
number of changes. The number of reportable
fields is increasing from 23 to over 60, the
number of asset class covered has broadened
and the buy-side is no longer exempt.
Q12 Will you be undertaking MiFIR transaction
reporting in-house?
More than half of respondents confirm that they
will be undertaking “in-house” MiFIR transaction
reporting, with a third advising they will not. The
remainder are still to confirm their approach.
In considering the above results, it is important to
note that under MiFID II, all reportable transactions
are to be reported through systems that comply
with specific requirements as detailed in Article
12 of the MiFID Level 2 Regulation. In practice,
what this means is that while a firm can perform
transaction reporting in-house, it will still need to
liaise with an ARM for the report to be submitted to
the relevant national competent authority.
Disclosure requirements
Key areas of MiFID II/MiFIR will require
increased disclosure of information to
both investors and regulators. Areas, for
example, such as:
• Costs and charges (with links to pension
and PRIIPs disclosure requirements)
• Best execution policies
• Product governance and inducement rules
• Recording and record-keeping requirements
• And transaction reporting
Q13 Will these requirements result in increased
costs and operational changes for your business?
Where the respondents are asked to identify which
requirements will result in both increased costs
and operational changes, transaction reporting
is flagged as the biggest impact with 74%.
Product governance and inducement rule
changes is the next item (67%) where a
large/substantial impact is considered.
In relation to impacts that are considered to have
a moderate effect, costs and charges disclosures
is the highest, ranked at 63%, followed by
recording and record-keeping, at 56%.
Q14 Have these requirements provided any
competitive advantages for your firm?
In the area of competitive advantage (for
these new requirements) asset managers
do not identify any areas that will provide
substantial benefits. Indeed all are identified
as providing either no different or only a
minimal benefit. However, 15% of respondents
say there are moderate competitive benefits
to be found in best execution policies and the
product governance and inducements rules.
Clock synchronisation
Transaction reporting
Recording and recod keeping
Product governance and
inducement rules
Best execution policies
Costs and charges
disclosures
No Difference Moderately
To a large extent/substantially
0% 20% 40% 60% 80% 100%