September 7, 2020

The FCA has released MW 65 with specific guidance on Transaction Reporting again!


“Transaction reports remain a fundamental part of our work to prevent, detect and investigate market abuse.“

“Our close supervisory oversight of the transaction reporting regime has led us to identify data quality issues;“

Issue FCA Comment CN Solution?
Unreported transactions Some firms have failed to submit transaction reports for transactions executed in non-EEA listed indices or baskets (composed of one or more financial instruments admitted to trading on an EEA trading venue). Y
Late Reports We have identified investment firms not having the infrastructure in place to submit transaction reports no later than the close of the following working day. Such breaches should be notified to the FCA promptly using the errors and omissions notification form. Y
Errors and omissions We do not expect firms to delay submission of the notification until the issue has been remediated and back reporting completed Y
Data service providers Where a data reporting services provider has indicated that it will stop providing a data reporting service, affected firms should make necessary arrangements to continue meeting their transaction reporting obligations. Y
The immediate underlying For derivatives the underlying should be reported with the ISIN of the immediate underlying instrument. We have observed where the ‘ultimate’ underlying instrument has been identified and erroneously used to determine reportability. Y
TVTICs: Venues We have identified inconsistent dissemination of TVTICs by trading venues to buyers/sellers. We recommend that trading venues review their procedures for the generation and distribution of TVTICs. Y (In QA)
TVTICs: Investment Firms We have encountered investment firms failing to report the TVTIC accurately. This includes instances where the field has been left blank, reported with an internal code, or reported with a code that fails to follow any guidelines provided by the respective trading venue. Y
Country of branch fields The country of branch for the buyer (Field 8) and seller (Field 17) should only be populated where the buyer or seller was a client of the firm. We have noticed firms reporting a country code in these fields where the buyer or seller was not a client of the firm, or using this field to highlight the geographic location or nationality of the buyer or seller. Y

Control Now covers all aspects of the FCA commentary.



“We expect firms to review their transaction reports to verify their completeness and accuracy.”

“Firms they should not assume a transaction report was accurate because it was accepted by the FCA. This is because our validation rules are not intended to identify all potential errors and omissions.”

“We remind investment firms that reconciling their transaction reports with front office records is a requirement in Article 15(3) of RTS 22.”

“We are encouraged by the number of data extract requests being made by firms for the purposes of reconciling their transaction reports with front office records.”


Control Now, founded in 2017, is a provider of transaction reporting assurance software tools to empower market participants to perform oversight of their regulatory reporting processes.