Reporting, reporting, and yet more reporting

While many European firms are still getting to grips with EMIR trade reporting and the headaches it’s caused, the next reporting challenge is already on the horizon in the form of MiFID/R.

It helps that MiFID/R does not require double reporting as long as the required information is reported once under EMIR. However, aiming to strengthen transparency, the scope of MiFID/R’s transaction reporting is wider than that of EMIR’s trade reporting and affects all financial instruments, not just derivatives. Even for instruments already captured – MiFID I equities and EMIR derivatives, for example – a number of new data items have been added. Among other things, the regulators ask for a designation to identify, where applicable, the computer algorithms responsible for the investment decision; the transparency waiver under which the trade was executed; and a short sale.

As well as keeping the regulators informed, firms also have to publish post-trade data. MiFID/R will extend the existing regime into assets such as ETFs, bonds, derivatives and structured products. The scale of the changes remains to be seen once ESMA and the European Commission pin down the details in Level 2. But, with establishing uniform requirements for transaction transparency firmly on the roadmap, the industry will be talking about reporting, reporting, and yet more reporting in the coming year.

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