In accordance with MiFID II and the implementing measures, Intermonte SIM will be required to report details of such transactions to the national regulators.
Transaction reporting is required by all MiFID-regulated firms for all financial instruments
admitted to trading or being traded on an EU trading venue; for which a request for admission to trading
has been made; or for financial instruments having an underlying financial instrument traded on an EU
trading venue. This is true in each case, even if such transactions are conducted away from a trading
venue or on a non-EU (third country) trading venue. The definition of trading venue includes MTFs and
RMs. With respect to Intermonte SIM’s relationship with its clients, the following should be noted:
Transaction reports: where two investment firms trade with each other, each will make its own
transaction report that reflects the transaction from its own perspective. For most sell-side firms,
this is nothing new. However, the new rules mean that investment firms that may have been
previously exempt from reporting, including many asset managers, will now have to report
(UCITS and AIFMD managers are out of scope for transaction reporting).
Reporting chains: the requirement that transaction reports reflect the transaction from each
investment firm’s perspective means it is imperative that the reports by Investment Firm A and
Investment Firm B mirror each other, otherwise the transaction reporting chain breaks and does
not provide the regulator with visibility of the whole transaction.
To satisfy MiFID II record keeping requirements, Intermonte SIM will enhance timestamps on relevant
records in accordance with millisecond granularity.
Conflict of Interest
MiFID II contains detailed provisions dealing with the identification and ongoing management of conflicts of interests. A concise report on the procedure for the management of conflicts of interest is included in annex 3.
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Intermonte SIM S.p.A. - Galleria De Cristoforis 7/8, 20122 Milano, Italia – Tel. +39 02 77115.1 – Fax +39 02 77115.300
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