Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities (Text with EEA relevance) (RTS 22) The Transaction Report Trade Reconciler performs completeness checks across large data sets within moments. For the purposes of reporting the transaction to an APA the seller should be the same as specified in field 16 of Table 2 of Annex I of RTS 22 (Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for . 59 Execution within the firm Individual ID . Regulatory Reporting BAU Operations experience and awareness of the following regulations is desirable (RTS 22 Transaction Reporting, RTS 2 Trade Reporting, EMIR and SFTR Reporting) Migrate BAU processes from other areas to TTR Operations, this will involve preparing operational procedures, workflows and preparing presentations and training the . RTS 22: Reporting of transactions to competent authorities. It will be interesting to see whether the EMIR review currently being undertaken by the EU legislators determines that there is a sufficiently strong argument to enforce ISO 22 for EMIR reporting as well. RTS 22: Reporting of transactions to competent authorities (Commission Delegated Regulation (EU) 2017/590) MiFIR 3rd subpara of Article 26(9) 28/07/2016 C(2016) 4733 : RTS 22: 22/11/2016: RTS 22 published in the Official Journal: Annex to RTS 22: RTS 23: Supply of financial instruments reference data (Commission Delegated Regulation (EU) 2017/585) 1. RTS 22 transaction reporting -Scenario 1: Participant record (DEAL) Field Trading on-venue RTS 22 Description Content Comment 4 Executing entity ID code LEI of AM 'ABC' LEI of Dealer 'A' 29 Trading capacity DEAL 7/16 Buyer/Seller ID code LEI of AM 'ABC' LEI of Dealer 'A' Has no client(s). For firms with access to the MDP and who were actually extracting data, 62% identified (and reported to the FCA) errors in their reports in 2020. 255/115/ 22% 240/51/51 . The transaction reports should be sent to the competent authority of the home Member State of the investment firm following Article 14 of the RTS 22 and the branch should be identified with the LEI of its head office even if it may be considered eligible for an LEI in some cases. They must conduct regular reconciliations of front office trading records with data samples provided by the FCA (RTS 22 Article 15(3)). At the touch of a button, market participants can efficiently reconcile transactions sent, from their front-office systems, to the regulator versus those received .

RTS 22 Article 15(2) requires firms to notify FCA promptly of errors. Is trade/transaction reconciliation a requirement by the regulator? The FCA takes the opportunity to remind firms of the importance of Transaction Reporting FCA published Market Watch 63 last week, and in it FCA details its views on market conduct in the context of Covid-19. The new rules are found in Article 26 of MiFIR and in RTS 22. Go Back Initiative Official name COMMISSION DELEGATED REGULATION (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of .

Date is YYYYMMDD. Annex I RTS 22 Annex I Table 2 p451 4 2015 ESMA Regulatory Technical and Implementing Standards - Annex I RTS 23 Article 3(1) p463 RTS 22 contains the main changes to firms' reporting obligations under the transaction reporting regime that arise because of Brexit. There are 65 data fields in the transaction report as set out in Annex I of Commission Delegated Regulation (EU) 2017/590 [former RTS 22]. While most of the fields can be populated using the transaction data of the respective trading systems, the information for some fields (standard case nine) needs to be added by the Transaction reporting: Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities (formerly RTS 22) (see here) "Investment firms shall have arrangements in place to ensure that their transaction reports are complete and accurate" - Article 15, RTS 22. The MiFID II directive and the MiFIR regulation entered into force on 3 January 2018.

The Transaction Report Trade Reconciler performs completeness checks across large data sets within moments. As part of MiFIR, there is an obligation for EEX Group exchanges to submit a daily transaction report for non-investment firms and third-country firms to the relevant National Competent Authorities (NCAs), i.e. Testing and reconciliations are mandatory under RTS 22, Article 15 We LEIs are required for the purpose of identifying counterparties that are legal entities (including those in trusts) in MiFID II transaction reports. Trax Report will inturn, submit a cancel and a new re submission - to the relevant NCA to effect the amendment of the report (see Section 2.5 below). MiFIR Article 26. Financial instruments falling within the reporting scope. The FCA continues to highlight Transaction Reporting data accuracy as a key area for improvement. ESMA has made it abundantly clear that investment firms must be able to identify a counterparty that is a legal entity in a transaction report by using an LEI and . The final version of RTS 22 was published in the EU Official Journal on March 31st, 2017. Meaning that most firms (78%) were in breach of the regulatory requirement under RTS 22 to regularly obtain MDP data for the purposes of reconciliation. - Suspensions. RTS 18 on the suspension and removal of financial instruments from trading reporting services providers; RTS 20 on the criteria to establish when an activity is considered to be ancillary to the main business; RTS 21 on the application of position limits to commodity derivatives; RTS 22 on the reporting of transactions to competent authorities illustrates technical standards for the reporting of transactions to competent authorities under MiFIR ("RTS 22"). This briefing takes account, in addition, of . When a transaction is submitted, Trax Report will check if a transaction with the same Executing Entity European Parliament and of the Council as regards recordkeeping obligations for investment firms, transaction reporting, market transparency, admission of financial instruments to trading, and defined terms for the purposes back-loading is 90 days after the obligation to start the reporting. Transaction reporting is required by all MiFID II Investment Firms (at a minimum). The deadline to report the transaction is the day after the transaction was executed, i.e. 2.6 Transaction reporting daily timeline 7 2.7 Transaction report submission 9 2.8 Manual transactions 10 3.0 Transaction Report Data 12 3.1 Member Portal static data 12 3.2 Trading scenarios 14 3.3 Fields Specification 17 3.4 Trade Cancellations 26 3.5 Client identification for natural person 27

Timing of reporting * To learn how to populate these fields and the "trading capacity" field, see our page on MiFIR Reporting for STP Brokers.

At the touch of a button, market participants can efficiently reconcile transactions sent, from their front-office systems, to the regulator versus those received . For example, where a firm collects a client's passport information but the passport is not one of the methods of identification stipulated within Annex II of RTS 22, the investment firm will have to request alternative identifiers from the client for the purpose of transaction reporting. Number of the original transaction. (RTS) 22[3], a piece of secondary legislation.

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