Reporting and Data
Reporting and Data
2.1 Order Record Keeping (All MTS Markets)
Under MiFID II there is a requirement to capture significantly more information from market participants, to enable competent authorities to fulfil their responsibilities to maintain orderly markets. This increased message content raises potential issues around system efficiency for member firms and trading venues, together with associated questions around data protection and confidentiality of personal data.
As a result MTS is considering ways of providing a technical infrastructure to map Short Codes for Trader and Algo ID Fields in order messages to the appropriate Long Code so as to better manage the impact of the increased dataflow on bandwidth and latency.
All participants will be required to provide this information in advance of trading to allow MTS to accurately reconcile data and identify orders sent to its trading system.
MTS will collect all data and submit it, upon request, to the competent authority.
2.2 Transaction Reporting
Transaction reporting obligations on investment firms are being extended under MiFID II beyond financial instruments listed on a Regulated Market to include financial instruments traded on other typologies of trading venues, such as Multilateral Trading Facilities (MTFs) and Organised Trading Facilities (OTFs), as well as any financial instrument which have instruments traded on trading venues as an underlying. UnaVista, part of the London Stock Exchange Group, intends to extend its existing transaction reporting service for MiFID II.
Additionally, trading venues are expected to report transactions traded on their platforms by non-MiFID member firms (including Non-EEA regulated firms or EEA asset management firms which are not covered by MiFID). For example, Societa’ di Gestione del Risparmio (SGR) in Italy.
In order to continue to allow the membership of non-MiFID firms under the rules of its markets, MTS is exploring technical solutions to collect all of the necessary information from those non-MiFID participants that are required to provide full transaction reporting by the trading venue to the relevant Competent Authority.
2.3 Reference and Market Data (Cash and BondVision)
MiFID II requires trading venues to provide complete and accurate reference data for all financial instruments “admitted to trading” to the relevant competent authority in electronic, machine readable format. Competent authorities will then send this data onto ESMA for publication on their website.
MTS will continue to provide real time, unbundled pre- and post-trade data on a reasonable commercial basis.
MTS trading venues will also provide delayed data free of charge 15 minutes after publication.
2.4 Quality of Best Execution (Cash and BondVision)
Trading venues are expected to provide reports on execution quality, free of charge and downloadable in a machine readable format, according to the templates defined in RTS 27.
Reports must be published four times per year (for each trading day that the execution venue is open for trading) and no later than three months after the end of each quarter. MTS is developing its arrangements to provide this data by making reports available on its website.
MTS is currently in discussion with the relevant competent authorities in order to ascertain whether this requirement will also apply with respect to securities financing transactions.
2.5 OTC Trade Reporting
MiFID II will introduce the obligation for firms to report all their OTC “off venue” trades within a specific timeframe; this will improve the transparency of trading activities to market participants. Trades concluded under the rules of a trading venue (“on venue” trades) are not subject to this requirement.
The London Stock Exchange Group (LSEG) has partnered with Boat Services Ltd to build a MiFID II compliant OTC Trade Reporting service. This new service is branded TRADEcho and offers customers a single, multi-asset, pan-European reporting solution that complements their on-venue trading activity and helps them meet their real-time MiFID II OTC trade reporting obligations.
TRADEcho will build on existing MiFID compliant OTC Trade Reporting services to provide a one stop shop for MiFID II OTC trade reporting across all asset classes.
London Stock Exchange will apply for Approved Publication Arrangement (APA) status, to facilitate Systematic Internaliser pre-trade obligations and OTC trade reporting under the TRADEcho service.
For more information please visit www.TRADEcho.com