18. Broker Reporting of Portfolio Manager Transactions

18.1. Reports are at the fund manager level not the fund level

The FCA has made it clear that transaction reports are to be at the portfolio manager level rather than at the fund level. As such allocations to funds do not need to be separately transaction reported.

18.2. Broker reporting of portfolio manager trades

So a broker submitting a transaction report for a transaction for one of the firm’s funds would be required to report the firm as the fund manager and not the details of the underlying fund.

Reporting firm Counterparty 1 Counterparty 2
e.g. BIC/FRN of broker Trade counterparty (broker or exchange CCP) e.g. BIC/FRN of the firm as portfolio manager

18.3. Inter-fund trades are not reportable

FCA do not require transaction reports to be submitted in respect of transactions between funds managed by the same portfolio manager where no broker is involved.[1]Transaction Reporting Forum, Jan 2011, slide 42 Inter-fund trades are not reportable.

   [ + ]

1. Transaction Reporting Forum, Jan 2011, slide 42