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16. FCA Discussion Paper 24/2: Improving the UK Transaction Reporting Regime

A detailed, opinionated walkthrough of FCA Discussion Paper 24/2, the most significant rethink of MiFIR transaction reporting since 2018, covering RTS 22, RTS 23 and the trading venue scope under Article 26(5).

/ Summary

We work through every major proposal, including the TOTV definition issue for OTC derivatives and the four candidate identification approaches (UPI+, modified ISIN, status quo), INTC linking code options, how to improve TVTIC matching beyond the current 71%, new client category fields, personal data on investment and execution decision makers, the Digital Token Identifier for tokenised securities, and the deletion of various indicator fields. Throughout, we share Control Now's own opinion on each proposal, which is useful as a benchmark for any UK transaction reporting head drafting their own consultation response. Includes live demos of AOTC validation and INTC reconciliation MI. The full 41 question appendix is included for reference.

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