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Last week, the Financial Services Authority (FSA) announced in its latest Market Watch Newsletter that the MiFID transaction reporting implementation date for the UK would now be the 5th November, a Monday, and not the expected 1st November, a Thursday.
The FSA, following discussions with reporting firms and trade bodies, has decided to move the UK implementation date for the new transaction reporting regime. This is on the basis that moving from a mid-week cutover will significantly reduce the implementation risk of both firms and Approved Reporting Mechanisms (ARMs) as they move to the new reporting regime. FSA-regulated firms will continue providing transaction reporting to their FSA-approved Permitted Reporting Systems (PRSs) in the current format up to and including Friday 2nd November.
MiFID requires all regulated transactions to be reported through systems which comply with specific requirements detailed in Article 12 of the MiFID Level 2 Regulation, defined as ARMs by the FSA. Currently reporting services are approved as PRSs on the basis of having the required fields, an agreed interface and beneficial impact to the firms and are listed in Chapter 17.7.8 of the FSA’s Supervision Manual ("SUP17"). MiFID changes these requirements so all the existing PRSs are having to re-apply to become ARMs and comply with MiFID.
From November 5th, firms will have to submit transaction reports in the new MiFID compliant format; old-style pre-MiFID transaction reports will not be allowed. The FSA has asked firms to make “all reasonable attempts to ensure their reporting at cutover is as complete as possible”.
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