Example: Transaction Reporting

BaFin complaints or error messages in reporting under Article 26 MiFIR often require a detailed root cause analysis, for which substantial knowledge of the regulatory requirements at Level 2 and 3 is required. If errors of a larger scale have crept in, a separate project and corresponding project support is often required. The reporting system according to Art. 26 MiFIR is much more complex than § 9 WpHG, at the same time it is more uniform throughout Europe and does not allow any special national solutions. As a consultant, I proceed in the following steps:

• Legal analysis of the transactions to be reported and the parties involved (Who has to report what?)
• Error analysis of the objectionable reports on the level of the XML files (What is wrong and where is the cause?)
• Analysis and determination of the need for correction of messages and systems (How many messages are affected?)
• Progress reports internally and to the supervisory authority (By when must the corrections be completed and how far are we?)

I build the bridge to the reporting department because I know both sides: the legal and the technical one. I know the reporting regulations down to the level of data field assignments and can carry out appropriate checks. I clarify internally and with the other party who should report what and how. If the Level 3 documents do not provide a solution, I can find a suitable solution by contacting the responsible BaFin department.