ESMA UPDATES Q&A ON MIFIR DATA REPORTING (July 2020)
On 8 July 2020, ESMA published new Q&A for MiFIR Transaction reporting.
The MiFIR Q&A contains two additional scenarios where an Investment Firm A executes a reportable transaction through an execution algorithm provided by another Investment Firm B (See Transaction Reporting Question 13).
The Q&A should not be read in isolation as further detail is provided in footnote 51 and must also be read in order to fully understand the reporting scenarios described.
Unfortunately, as has been well documented in the past, change to ESMA Q&A are effective immediately with no grace period for implementation.
There is no impact on ESMA validation rules to accommodate these new scenarios and hence no change to the service delivered to ARM clients but we recommend that clients cross check their booking models against these new scenarios to ensure they continue to report correctly.
Useful links for more information: https://www.esma.europa.eu/sites/default/files/library/esma70-1861941480-56_qas_mifir_data_reporting.pdf