March 27, 2019

Goldman Sachs fined £34,344,700 for failing to provide accurate and timely reporting relating to 220.2 million TRs between November 2007 and March 2017. (Reduced from £49,063,900). The summary of their misreporting is;

  • 204.1 million inaccurate report
    • 11 different issues – see attached.
  • 9.5 million under reports
  • 6.6 million over reports
  • 15% of all reporting affected

Change management

“The Authority expects firms with transaction reporting obligations to keep these under review and to update their processes accordingly. It is therefore important that firms take reasonable care to implement robust change management processes that are designed so that any changes in the regulatory rules which require interpretation by firms do not impact upon the accuracy and completeness of the reported transactions.”

[MA 25.04] – we should make a selling point out of this – review TRA and TRC and identify how they can be used to test changes havent had adverse affects. Perhaps we build a diff tool also?

Reference data

the Firm failed to take reasonable care to ensure that it had sufficient systems and controls to maintain the accuracy and completeness of counterparty reference data used for transaction reporting.”

“the Firm did not have a fully automated process for reviewing or updating all of the existing entity records held within their database to confirm whether a BIC or FRN was or had become available.”