Transaction Reporting

A fairly short edition of Market Watch concentrates on transaction reporting issues.

MiFID investment firms are reminded that they need to have a BIC-see Regulatory Roundups 17 & 11 for further details on this. It is proposed that the option to identify entities with an FSA Reference Number (FRN) will be removed. The FSA will consult on this during 2011.

Following a rethink, the FSA will no longer require portfolio management firms to transaction report inter-fund transactions. The Transaction Reporting User Pack (TRUP) will be amended accordingly (see second bullet in s7.4.1 of current TRUP).

The FSA advise that they receive ‘a significant number’ of OTC derivatives transaction reports without the underlying ISIN being provided. It is therefore proposed that an additional validation will be introduced requiring the ISIN to be provided when instrument types X (other); F (future); or O (option) are selected. The FSA ‘will give the industry enough notice before the change becomes effective’.

Elsewhere the paper covers: the need for firms to regularly review the integrity of their transaction reports; monitoring obligations when reporting is outsourced; and a proposed change to CDS pricing reporting.