MiFIR Transaction Reporting Guide For Financial Institutions

Are you contemplating whether to get started as a financial market trader or are you looking to comply with the updated MiFIR regulations? There are many frequently asked questions (FAQs) in the minds of many businesses about MiFIR that remain unresolved. Here is a caption of some of the questions that could be lingering on your mind and how you can navigate them.

Are transactions Reported Separately under MiFIR and EMIR?

Well, both reporting regulations require that transactions are reported as long as it is reportable instrument (under EMIR) or provided it is a venue-traded underlying financial instrument (under MiFIR).

Is there an Overlap Between MiFIR and EMIR Trade Reporting?

Yes, there is a significant overlap as to the extent of reportable data such as the prices, amount of transaction etc.). However, the MiFIR Transaction Reporting goes further to require more information such as the identification of the client and collaterization. Clearly, no single regime exhaustibly conveys the data requirements of the other.

Do the Reports Relating to MiFIR and EMIR End Up to The Same Authority?
No. MiFIR reports are usually send to an Approved Reporting Mechanism (ARM) or may be sent directly to the National Competent Authority (NCA) whereas EMIR reports end up to the Trade Repositories (TR). However, some middle agencies may act on behalf of both ARM and TR to facilitate the collection and forwarding of reporting information.

What are the objectives MiFIR and ARM?

The EMIR is concerned about reducing the systemic risks that are associated with financial markets and works to prevent any possible collapse of a financial system. On the other hand, the MiFIR is focused on detecting market abuse by financial institutions, protecting the investor, and enhancing the efficiency of financial markets. It is without a doubt the MiFIR is investor-centric while EMIR is market-centric.

When Should One Publish Post-trade Information?

According to the regulation, such information should be reported or published in near real-time as it may be technically practical. Here are some of the parameters that guide this regulation:
• On or before 3rd January 2021, organizations should report within 15 minutes following the execution of the transaction
• After 3rd January 2021, the reports should be made public within 5 minutes after passing a transaction

What Should be Published in a Post-trade Report?

• The date and time of trade
• Instrument identification code
• Unit price Quant of transaction
• Venue of publication
• Venue of execution
• Price currency

Now you have every reason to comply and avoid punitive measures of non-compliance to MiFIR and EMIR regulations relating to MiFIR Transaction Reporting.

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