Transaction Reporting 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.