2. What are the FCA Transaction Reporting Requirements?

2.1. Background

Chapter SUP 17 (Transaction Reporting) of the FCA Handbook Supervision Manual requires UK regulated Firms entering into reportable transactions to send to the FCA before the close of the next business day transaction reports containing mandatory details applicable to those transactions. The end of the business day is deemed to be the last point at which the Approved Reporting Mechanism (“ARM”) is able to submit a transaction report to the FCA. For example, the ARMs Xtrakter and UnaVista have a cut-off of 10pm.

The FCA also exchanges certain transactions with other regulators. For example, all EEA branch activity reported to the local host regulator is sent through the ESMA Transaction Reporting Exchange Mechanism (“TREM”) to the FCA. Similarly, FCA will send any of the firm’s transactions in non-UK instruments to the primary competent authority, for example, transactions in BSAF are forwarded through TREM to the BaFIN.

2.2. Transaction reporting arrangements within firms

As in previous versions of the Transaction Reporting User Pack (TRUP) there is guidance on the FCA’s expectations in respect of reporting firms’ controls over the accuracy, completeness and timeliness of their reporting. TRUP 3.1 is more explicit than previously and sets out expectations in respect of the training that those involved in transaction reporting are expected to have (including elements of the training content) and the expectation that firms will conduct front to back reconciliations between front office systems and the reported transactions.

Whilst many firms will already have controls in place, a review of the controls and whether they satisfy all the areas outlined in the TRUP is recommended.