Transmission
of orders – implications for buy-side : Basic trading scenarios (D1 to D7 -T
1 to T3) scenarios will be explained in next blog article, Note these
example are simple capital market product buyer side scenarios and nothing
SHOULD be linked to any organisation or company . These examples are purely my
own production form training and study and research
ongoing on this topic.
1. Front
Office <Removed - to be updated later >
2.
Middle office for DMS settlements
3.
Data Mart / Reporting
4. Reporting engine communication/ Real time
ASP, Key stroke synchronism correspond to operational AREA status and
Conf of Business partner/ references data
5. Exception Pre- Reporting. -traded
obligation between staging data mart before transmission to avoid failure,
major validation area
6. Pre-sumission validation
results (Key validation here for each and every transaction rules probably
might be aligned to ARM before MIFR ARAM
6a Actual submission
in destination format accepted in the ARM solution
Above diagram do
not goes into Pre traded validations which are unique to individual organisation
trading infra.
Reference Data
standards
In
the buyer and seller fields, Buyers and sellers can either be reported as legal
entities (i.e. investment firms or legal persons), or natural persons. As
above, where the buyer or seller is a legal entity, they need to be identified
using an LEI, which needs to be reconciled against the global LEI database
before engaging in any reportable transactions. This is particularly important
when an investment firm is trading on behalf of its clients, as the firm will
need to collect and verify the LEIs provided by its clients in advance of any
trading. Where the buyer or seller is a natural person, their first name,
surname and date of birth are required in the report. Firms will need to gather
and normalise this information from HR databases, before compiling transaction
reports. To ensure best practice, they should also reconcile any responses from
the reporting venues to make sure the data is accurate. Additionally, under
MiFIR, firms will need to identify the person or entity that made the decision
to buy or sell the instrument in the first place. This will require
considerable work to record the relevant data in front-end systems, and then
robust data controls to ensure it remains accurate throughout the lifecycle of
the trade. Whether an individual or a group of people make the decision to
trade, the firm must report the one person considered to have primary
responsibility for the transaction. This person needs to be identified by their
ID number, passport number, tax or national insurance number depending on their
nationality. Or, in the absence of these, by a concatenated code consisting ++
The
main executor of the transaction must also be identified – using the same
system. Where the decision to trade, or the execution of a transaction, is
carried out by an algorithm, that algorithm must be identified using a unique,
consistent and persistent code. This enables regulators to track all
transactions carried out under a particular strategy, and also ties in with
other areas of MiFID II which stipulate that firms must have controls in place
to ensure the auditability and resilience of their algorithms. These extra
identifiers will require new data to be captured at the point of execution, and
then passed to middle and back office Systems
to ensure consistency of reporting
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