MiFID II trade and transaction reporting support for cash securities, fixed income and OTC derivatives across asset classes for a large European Bank
Client : Large European Bank
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Objective
To implement MiFID II trade and transaction reporting for cash securities, fixed income and OTC derivatives.
Challenges
Ambiguity in the regulatory text and lack of regulatory guidance on certain key drivers of the regulation
Lack of consensus among the industry with respect to interpretation of certain aspects of the regulation
Need to map trade source systems fields to the required regulatory fields, especially for OTC derivatives like commodities
Non-availability of certain reference data for OTC derivatives from existing vendors
CRISIL's Solution
Business requirements definition
Defining the detailed business requirements for trade reporting, transaction reporting and reference data
Mapping the regulatory fields to the source system fields at an asset class level
Functional requirements specification
Defining the functional requirements and use cases
In-depth analysis of mapping all the MiFID II fields for each and every product traded under every asset class
User Acceptance Testing
Tested the trading systems for completeness and accuracy of reporting
Tested various lifecycle events and amendments on the trades
Regulatory Operations
EOD reconciliation between the source system trades and the trades processed in the reporting engine
Tracking the issues with the source systems and capturing the relevant reasons for failed transactions for reporting
Client Impact
CRISIL helped our client meet its reporting requirements by ensuring all regulatory requirements were either implemented or raised to the regulators as compliance challenges with clearly defined processes for addressing them in the future.
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