FIA has submitted its response to ESMA’s Consultation Paper on “Guidelines on transaction reporting, reference data, order record keeping & clock synchronisation.” FIA’s response primarily concentrates on the transaction reporting section of the consultation. At a high level two main concerns were raised:
- FIA members feel that firms operating centralised reporting infrastructures (where they report for a number of group entities) should not be required to register as an ARM (Approved Reporting Mechanism). Centralised reporting infrastructure in an already regulated firm brings a number of benefits for both regulators and firms, including cost efficiencies and a reduction in operational risk.
- Reporting of collateral movements: FIA members feel that the reporting of collateral movements would add little or no value from a market abuse monitoring perspective and would in fact just add in additional noise to the reporting regime
The response also details a number of ETD (Exchange Traded Derivative) reporting scenarios where we seek clarification that our reporting interpretation is correct, as well as addressing a number of other issues.
