FinfraG Article 39 Post Trade Transparency Trade Reporting support for cash equities and fixed income for a large European Bank
Client: Large European Bank
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Objective
To implement FinfraG Article 39 Post Trade Transparency Trade reporting for cash equities and fixed income.
Challenges
Requirements traceability: Implementing provisions for a requirement spread across multiple regulatory documents made it difficult to analyze and trace requirements
Ambiguity in the regulatory text and definition of few key terms made interpreting and understanding the regulation a challenge
Lack of clear regulatory guidance
CRISIL's Solution
Understanding the background
Conducted detailed study of trade reporting regulation with implementing provisions in FMIO, FINMA-FMIO, FINMA;
Sought out compliance team advice and industry confirmations on our interpretations/assumptions for ambiguous regulatory texts;
Liaised with industry vendors to define reporting process in light of similar regulations like MiFID II already in place;
Held regular discussions with working group to understand the impact from stakeholder perspective.
Defining the business requirements
Defined requirements for trade reporting and reference data;
Identified the entities/branches/products and business scenarios or executions in scope of the regulation and converted them to business requirements;
Mapped the regulatory fields to the fields in the source systems of the client to ensure accurate reporting for cash equities and bonds.
Defining the functional requirements
Converted business requirements into functional requirements, use cases and scenarios;
Defined the logic for sourcing the unavailable reportable fields from trading systems/ reference data or maintaining them in-house.
Client Impact
CRISIL helped the client comply with a complex and poorly defined reporting rule by ensuring all the regulatory requirements are were properly interpreted, understood, documented and communicated to various stakeholders for proper implementation and compliance.
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