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MiFID RTS 22 on Transaction Reporting and FCA reporting system

On 28th July 2016, the European Commission published the final version of Regulatory Technical Standard(RTS) 22 of MiFID II, which specifies the way in which Investment Firms must report data to National Competent Authorities(NCA) under MiFID II. All Investment Firms are subject to the “Transaction Reporting” rules and must report data to  NCAs, in many cases via Authorised Reporting Mechanisms(ARMs). The requirement will apply to any energy and commodity market participant that either elects to, or is required to set up a “regulated entity” under MiFID II, due to the results of the (as yet non finalised) Ancillary Activity test.

This article on the Eversheds web site provides a summary of the requirements. The RTS can be found here, and the supplementary Annex with the field list here.

In the meantime, the FCA (UK NCA) have made this announcement of their new Market Data Processing system, to be used by them for all MiFID II data. This includes not only transaction data as referred to above, but also commodity derivative position reports, for those who must submit the data, as outlined in MiFID II ITS 4 and 5. It also includes other MiFID II items such as transparency data. Those who will send the data directly to the NCA, as opposed to one of the indirect routes, will need to use this portal for UK activity.

About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.


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