BJSS white paper helps firms avoid the pitfalls of a changing regulatory landscape
With global regulatory reform driving change in the financial markets, trading organisations must face up to a number of imminent challenges, particularly around transaction reporting. Firms must act now if they are to avoid the significant fines and reputation damage that others have suffered for non-compliance. In response to this need, BJSS, an established IT consultancy in the capital markets, has published a white paper outlining how firms can best prepare their systems for the new wave of demands.
Firms must first understand the full impact that multiple regulatory changes will have on their transaction reporting. These include the ongoing implementation of MiFID, which introduces a reporting requirement for ‘Flex’ contracts; the G20 requirement to report OTC derivative contracts to trade repositories by 2013; the imminent MiFID II reform which is set to extend regulation across multiple asset classes and introduce additional transaction reporting obligations; plus the Regulation on Energy Market Integrity and Transparency (REMIT), which is expected to introduce new reporting requirements for wholesale energy markets in 2013.
Mike Bates, managing director at BJSS, explains: “These changes have the potential to cause major confusion as they overlap with existing reporting regimes. Firms may find they have to report a single trade to multiple European regulators, such as ESMA and ACER, as well as to trade repositories in the US and Europe. To address the complexities of generating transaction reports that meet these regulators’ requirements, firms need to pay close attention to the systems involved in the testing of transaction reporting.”
Details of previous FSA fines for invalid transaction reporting reveal some common failings. These include incorrect market details, such as reporting the wrong side of a trade or against the wrong time zone, inadequate business processes, such as not building and testing a process for managing rejected trades, and inconsistent reference data. A reporting firm was fined £1.75M by the FSA for failing to keep reference data current following a change in market identifier codes for Milan and Stockholm exchanges, alongside multiple other reporting failings.
In its white paper, ‘Adapting Testing Approaches for Regulatory Transaction Reporting’, BJSS outlines several steps firms can take to address their trading and back office infrastructure. These include the early engagement of testing, which is paramount to effectively identify and resolve requirement gaps in good time; effective sourcing and integration of reference data, which is a key requirement that should not be underestimated; independent testing, to ensure outsourced providers also achieve regulatory obligations; and embedded transaction reporting domain experts within the delivery team to reduce the risk of common compliance problems.
Mike Bate adds: “These regulatory changes present a valuable opportunity for IT departments to learn from the previous mistakes of other firms. While some of the changes may seem minor in terms of the technical requirements, firms should not ignore the broader issue of establishing a holistic strategy for testing. Without this, they may be vulnerable to risks from an unnoticed impact to existing reporting functionality or a third party’s failure to comply. These can have serious and far-reaching reputational and financial implications.”