ESMA has provided a very useful example of how to report FX forwards in its latest Q&A on MiFIR data reporting. In particular, we would urge firms to take note on the practice of populating the ‘quantity’ and ‘price’ fields:
- The ‘quantity’ (and ‘quantity currency’) should reflect the amount of the FX forwards in the base currency
- The ‘price’ (and ‘price currency) should show the forward rate expressed as a price of base currency in the quoted The monetary value XML tag should be used (if reporting to an ARM in flat file, ‘price type’ is monetary value.
The only additional changes appear to be in the table of national identifier formats. This details a change in the format of Portuguese passports issued after April 2018 and corrections to the Romanian National Identification Number and national passport formats.
Whilst the new MiFIR Q&A signals only relatively minor changes, it clearly demonstrates the need for firms to remain on top of regulatory developments. Our regulatory reporting training courses help firms stay abreast of the reporting requirements and help identify any interpretational errors. For further details, please see our training courses.