How will your firm comply with its MiFID II transaction reporting obligations?

With the rules set to come into force on January 3, 2018, time is running out for firms to ensure they have a robust and properly tested solution in place.

And the cost of non-compliance is steep. The UK’s Financial Conduct Authority, for instance, has previously charged a £1.50 fine per line of incorrect or non-reported data, notes regulatory think tank JWG [1]. That can soon add up … as Merrill Lynch’s recent £34.5m fine for historic reporting failures under the EMIR rules shows.

Transaction reporting with SS&C Advent

To enable clients to meet their T+1 transaction reporting requirements, we’ve partnered with UnaVista, the London Stock Exchange’s Approved Reporting Mechanism (ARM). UnaVista offers a tried and tested ARM service that reports transaction details on every reportable asset class to National Competent Authorities on investment firms’ behalf [2].

Thanks to the connectivity we’ve built between Moxy and UnaVista, the reporting process is seamless and straightforward. Once daily transactions are completed, a standard transaction file can be generated from Moxy to upload to UnaVista through its Secure File Transfer Protocol (SFTP). UnaVista then runs its own validation checks before submitting the report to the regulator.

Status updates are available through UnaVista’s portal. Here users can see, for example, how many transactions have been reported, or how many were blocked because they weren’t eligible for reporting. If there are any exceptions, users can rectify those transaction details through the portal.

The service is also GDPR sensitive. While a lot of personal information needs to be included in the MiFID II transaction reports, clients can maintain a data mapping table at UnaVista’s end that includes all the necessary personal details. So rather than provide all that information in the Moxy file extract, we send a code that matches one held in UnaVista’s mapping table. And because those mapping table details can only be accessed and changed by authorized personnel at the investment firm, users retain control over all their personal data.

Two access options

There are two main ways our clients can take advantage of the UnaVista service:

i) DIY option—this allows clients to manage the service process in-house. They then have responsibility for extracting the transaction files from Moxy, ensuring they are uploaded to UnaVista, monitoring the portal, managing any exceptions and maintaining the mapping table.

ii) Managed service through Advent Outsourcing Services (AOS)—the reporting process is the same, but our dedicated team takes on the burden of those technical and operational servicing duties on clients’ behalf.

Eliminate the fear of non-compliance

Through AOS, we ensure all the transaction files are generated correctly, that no values are missing, and that they are uploaded properly to UnaVista within the required timeframes. We also monitor the portal, fix any problems, and manage the mapping table if required.

That means you don’t have to train a member of your operations department to manage the process, and redirect them from their other primary responsibilities. There is no ‘key person risk’ if that staff member goes on holiday, is reassigned, or leaves your firm.

Plus you get to take advantage of the knowledge and experience of our expert AOS team.

Because we manage the process for multiple clients with diverse profiles, we have a deep understanding of industry best practices. We will also ensure our platform and processes always remain up-to-date with the inevitable, often incremental, rule changes that may be introduced over time, and that are all too easy to miss if this is not your core activity—enabling you to stay compliant with your transaction reporting responsibilities and avoid any of those costly fines, whatever the future holds.

To learn more, please contact us at advent@sscinc.com.

[1] Getting new MiFID II reports wrong could cost millions, by Eman Galea, JWG, 24 October 2017
[2] Find out more about UnaVista