MiFID II / MiFIR Transaction Reporting A Practical Guide

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Short selling indicator Used to indicate a short sell where the seller is the reporting firm or its client. Also indicates whether the short sale was undertaken under an exemption from disclosure obligations as defined by the Short Selling Regulation (SSR). SESH Short sale with no exemption SELL No short sale SSEX Short sale with exemption NTAV Information not available OTC post-trade indicator Used to indicate the type of transaction. Many of these also relate to data requirements under EMIR trade reporting. The field can be populated by one or more of the following: BENC Benchmark transactions ACTX Agency cross transactions NLIQ OILQ Negotiated transactions in liquid financial instruments Negotiated transactions in illiquid financial instruments NPFT Non-price forming transactions LRGS Post-trade large-in-scale transactions ILQD Illiquid instrument transaction SIZE Above specific size transaction CANC Cancellations AMND Amendments SDIV Special dividend transactions RFPT Reference price transactions PRIC Negotiated transactions subject to conditions other than the current market price ALGO Algorithmic transactions RPRI Transactions which have received price improvement DUPL Duplicative trade reports TNCP Transactions not contributing to the price discovery process TPA Package transaction XFPH Exchange for physical transaction Clearly there’s a large quantity of new data here that needs to be obtained, normalised and reconciled, from a wide variety of sources. MiFID II / MiFIR Transaction Reporting A Practical Guide
The cost of non-compliance In recent years the increase in the size of fines for firms failing to comply with MiFID I regulations has been notable. While regulators may have given firms some leeway regarding breaches in the past (when the regulations were fairly new) it now seems that infractions are being dealt with far more heavily. Indeed, following the Merrill Lynch fine, the FCA indicated that the penalty for transaction reporting non-compliance will now increase from £1 to £1.50 per breach, to ensure the industry takes more care over their reporting requirements. While the delay to MiFID II and MiFIR’s implementation date may seem like a blessing, it could well make regulators less inclined to forgive early mistakes. Financial penalties for transaction reporting failures Merrill Lynch April 2015 Incorrectly reporting transactions and failure to report transactions between November 2007 - November 2014 RBS July 2013 Incorrectly reporting transactions and failure to report transactions Deutsche Bank August 2014 Incorrectly reporting transactions £5.6m £4.7m Barclays September 2009 Failures in transaction reporting Credit Suisse April 2010 Failure to provide timely and accurate transaction reports £1.75m £13.3m £2.45m Société Générale August 2010 Failure to submit accurate reports for approximately 80% of its reportable transactions, across all its asset classes, for over two years £1.6m Source: “MiFIR reporting requirements: Not for the fainthearted”. Aite Group, April 2015 MiFID II / MiFIR Transaction Reporting A Practical Guide
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MiFID II / MiFIR Transaction Reporting A Practical Guide

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