When Mifir expanded the scope of reportable transactions, investment firms were not only tasked with upgrading systems to send a vast amount of reports but also ensuring those reports can be successfully reconciled against the regulators’ records.
For the first six months of the year, UnaVista product manager Alexis Wiazmitinoff observed the latter was less of a priority for firms, who were more focused on reconciling against transactions held at the approved reporting mechanism (ARM).
“Firms were less focused in reconciliation against the regulator’s record in the first half of the year, as they were still concentrating on meeting their new reporting obligation under Mifir,” he said.
“Now, clients understand the need to focus on the completeness and accuracy of the data held at the regulators, as regulators start making transaction extracts available.”
UnaVista Mifir Reconciliation Tool
The Mifir reconciliation tool allows multiple parties not only to reconcile their trade reports against transactions reported to UnaVista’s regulated ARM, but also against the regulators’ reports.
“UnaVista’s reconciliation tool ultimately allows for a three-way reconciliation to be run on reported Mifir transactions,” Wiazmitinoff said.
This comprises client versus ARM, client versus national competent authority (NCA) and ARM versus NCA reconciliation.
Leveraging LSE Group technology, the tool facilitates straight-through processing, allowing for break resolution based on a set of pre-defined criteria on any of the Mifir fields.
“This significantly reduces risk of non-compliance with RTS22 (Article 15) requirements,” he added.
Article 15 requires firms to reconcile front-office trading records with trade data provided by NCAs, or from the ARM if data from the regulator is not available, to identify any instances of inaccurate or incomplete reporting.
To cater for these time-sensitive requirements, UnaVista allows firms to use a service that maps their format to the one recognised by the tool if they cannot apply UnaVista’s format.
The tool also reconciles Mifir personal information fields, in accordance with the latest data privacy regulations.
“We have also taken measures to protect personal data. We hash the data when it is extracted from the ARM as well as client data, so we are matching at a level of anonymity,” Wiazmitinoff said.
UnaVista is already planning to extend the service beyond Mifir reconciliations once the latest round of updates are delivered.
“We will be looking at extending the solution to cover further regulations, starting with Emir,” Wiazmitinoff said.
“We will also be looking at adding the ability to reconcile Mifir instrument reference data reports against Mifir transactions.”
Another area of focus for UnaVista will be extending its regulator extract coverage across the EU27.
At present the tool supports reconciling against extracts from the UK Financial Conduct Authority but the plan is to support extracts from Central Bank of Ireland and the French AMF for clients with reporting obligations in Ireland and France next year.
“Our Mifir reconciliation tool is a non-regulated service, so clients will be able to use this as a mechanism to reconcile multiple data sets post-Brexit regardless of where the data is held,” he explains.
The biggest challenge will be for UnaVista to establish cross-border connectivity and interoperability with regulators’ platforms once the regulators allow data to be pulled automatically.
10-year anniversary and beyond
UnaVista celebrates its 10-year anniversary this year. Having been established as a data management platform, it went on to become one of the leading regulatory reporting platforms within a decade.
One of the priorities during its second decade will be to bring added value to operations that were once considered an onerous cost – data analytics is at the heart of this.
UnaVista is set to launch new services in 2019 which include data insights into trading patterns and the ability to compare the quality of a firm’s transaction report against their peers.
Technologies such as artificial intelligence will become increasingly relevant as the industry seeks to better understand the data that is being analysed and improve the quality.
Now that reporting firms are used to reporting and regulatory change, the next phase for UnaVista is to take a more sophisticated look at what is being delivered and what value it is bringing.