FCA insight into Transaction Reporting Feedback

At the Infoline Trade and Transaction Reporting Conference in London this week the audience were on tenterhooks for the latest update from Ana Fernandes, MRT Manager at the FCA. We thought we would share some insight from the statistics and issues she highlighted:


  • There are over 8.7bn records in the FCA’s Market Data Processor (MDP)
  • There are 23 submitting entities
  • Approximate 7,900 executing entities under ESMA, 3,000 of these are UK firms
  • Over 300,000 LEI’s and over 6.7m National Identifiers
  • FCA has received 1,335 notifications of errors from only 394 firms
  • 20 thematic investigations have been completed
  • 130 firms have been contacted by the FCA
  • FCA have only seen 405 requested and downloaded sample Transaction Reports in 2019

There was a definite concern on the low numbers of submissions and an encouragement for firms to come forward asap and ‘promptly notify’ as per stated in Article 15(2) of the RTS 22.

Issues seen by the FCA

  • GMT vs BST (a candid reminder to firms that clocks do change twice a year!)
  • Major vs Minor currencies
  • Price Zero vs NOAP
  • Buyer vs Seller
  • Misreporting of National Identifiers
  • Wrong Buy/Sell with Trading Capacity
  • Inconsistent TV TIC by Trading Venue
  • Use of default trading times

Food for thought especially as mentioned before, by my colleague David Nowell, that these are still the same issues that firms were fined for as seen under MiFID I. These facts and issues evidence that the FCA are actively pursuing policy and detective activities in order to identify data quality issues. These are issues Kaizen testing is designed to highlight to our clients. Get in touch to discuss the accuracy of your trade and transaction reports.