MiFID II/MiFIR: Reporting for Financial Institutions
Authored by: Silvano Stagni, Global Head of Research at Hatstand, a Synechron Company
Reporting is often considered to be the main part of regulatory compliance. MiFID II/MiFIR differentiates between reports that need to be delivered to ESMA, National Regulators or to Authorised Publication Authorities (APAs) on a regular basis and lays out the record keeping rules. This includes the order book, where data needs to be made available to National Regulators on demand but there is no obligation to provide an actual report on a regular periodic basis.
The most complex part of the reporting processes is ensuring that the correct data is available at the right time. Change relating to all aspects of data is the most disruptive part of the MiFID Review. The regulatory scope is extended to non-equity products, and there is a wider use of the Legal Entity Identifier (LEI). There is a requirement to identify and classify financial instruments. There are more ‘roles’ to identify.
This paper looks at the reporting obligations of a financial institution under the new regime of MIFID II/MiFIR. We start with a summary of what financial institutions have to comply with and then look at each report in isolation.
Reporting and Record Keeping
The difference between reporting and record keeping is that the former has a frequency (real time, daily, monthly, quarterly, etc.) whilst the latter has to be made available on demand. The former has recipients such as National Competent Authorities (NCA), Authorised Publication Agencies (APAs), clients, etc. whilst the latter needs to be entered and stored in a format that can be made available on request in a timely fashion.