One of the most interesting statements from the FCA Final Notices following the recent fines for MiFID transaction reporting breaches concerned the general lack of expertise around transaction reporting in the industry. The firm impacted was clearly trying to do the right thing, but was hampered by “…a scarcity across the Firm and the industry of personnel with the expertise and systems knowledge required both to implement the enhanced controls and remediate the issues identified during the course of the project”¹
It is difficult to understand why this lack of expertise should still afflict such an important area of compliance. Whilst it may not appear to be the most glamourous area of regulation, the FCA has shown a continued willingness to take action against firms for breaches. Many of the errors highlighted by the FCA appear to have been simple mistakes in the interpretation of the reporting requirements and might have been avoided through a more effective training programme. It should also be remembered that these fines relate to the old MiFID transaction reporting which is relatively simple compared to the greatly increased scope and complexity of the current MiFIR transaction reporting regime.
Help is at hand
At Kaizen, we believe effective training is an essential element in ensuring complete and accurate transaction reporting. We offer a half day CPD-accredited training course, endorsed by the Chartered Institute for Securities and Investment (CISI), which gives candidates a core understanding of the transaction reporting requirements and the fields that comprise a transaction report. The course can be taken at Kaizen HQ or at your own offices and is accompanied by an exam which enables you to demonstrate your understanding of the reporting requirements. Similar courses are available for EMIR trade reporting and SFTR. Visit our training page for further details and to book your place on one of our upcoming scheduled dates.
Are you a Transaction Reporting guru? Why not take part in #TransactionReportingTuesday over on LinkedIn.
Every Tuesday, on the Kaizen LinkedIn we will be publishing a MiFIR Transaction Reporting question from our training exam. The answer will be posted a week later along with a new question.