We have a product release due on the 09.04.21 at 1700 UK local time.

KEY POINTS

• Natural Persons identifiers no longer used in ‘Clients’ reference data (CRD_CL).
• EMIR – 3 new MI’s, 1 enhancement to existing MI, 2 fixes to existing MI, 4 validation amendments, 1 deleted validation
• MiFIR – 10 new validations, 12 validation amendments, 5 deleted validations
• Reference data changes: Blacklist reference data is now available for EMIR validations
• 1 new generic MI: details on Blacklisted items on all regimes
• 1 change to Client reference data: new field added to Client Configuration

WHAT DO YOU NEED TO DO?

Update your Client Configuration reference data (CRD_CL_CFG_) by adding an additional column ‘discretionary_investment_manager’ at the end of the file.

This can be completed directly in the grid editor if you are storing your reference data file in the Portal.

New field is relevant to MiFIR reports and should be populated with ‘Y’ or ‘N’ indicating if the reporting counterparty is providing discretionary management service for their clients.

 

Ref	Product	Change	Summary	Client Description	Issue key
1	Accuracy: Reference data	Reference data	Add a new field to ‘Client_configuration’ client ref data	New field ‘discretionary_investment_manager’ being added to ‘Client Configuration’ reference data file. Field allows to introduce new validations specific to reporting firms only providing discretionary management service for their clients.	TRD-262
2	Accuracy: Reference data	Reference data	ISIN Blacklist Ref data: Allow for all validations	Enabling the use of ‘Blacklist’ reference data for EMIR validations.	TRD-8
3	Accuracy: EMIR	New MI	New EMIR MI: Confirmation	New EMIR MI summarising requirements for trade confirmation and displaying details of trades where requirement was not met.	TRD-133
4	Accuracy: EMIR	New MI	New EMIR MI: Maturity dates	TRA EMIR: new MI displaying whether Maturity Date was populated with a break down for instrument classification.	TRD-119
5	Accuracy: EMIR	New MI	MiFID & EMIR Report output – new csv report ‘BLACKLISTED_DISABLED’	Added new optional report displaying all reports that would be flagged by disabled validations and exceptions to validations managed by client via Blacklist.	TRD-103
6	Accuracy: EMIR	New MI	New EMIR MI: OTC FX Derivatives Buy/Sell	A new EMIR MI report to help firms monitor they are reporting correctly where the underlying is a currency. In the case of cross-currency swaps and swaps and forwards related to currencies, the counterparty receiving the currency which appears first when sorted alphabetically by International Organization for Standardization (ISO 4217) standard shall be identified as the buyer and the counterparty delivering that currency shall be identified as the seller. (ITS, Article 3a(6))	TRD-74
7	Accuracy: EMIR	Fix: Validation	E107 – exception for unknown underlying bond	Amending validation to not flag where underlying is a government bond that’s not present in FIRDS.	TRD-291
8	Accuracy: EMIR	Fix: Validation	E143 – exception for unknown underlying bond	Amending validation to not flag where ISIN suggests that underlying is a bond, but there isn’t enough information to determine issuer of the bond (government).	TRD-290
9	Accuracy: EMIR	Fix: Validation	Add exceptions to E90	Fixed issue with validation where false positive results are received for Asset class = IR where traded products are: caps, floors, cross currency swaps or where underlying is a government bond or where underlying is unknown.	TRD-289
10	Accuracy: EMIR	Fix: Validation	E90 double flagging with E141, E142, E143, E144, E145	Amending validation to avoid double flagging when one of the related validation has already been triggered	TRD-288
11	Accuracy: EMIR	Enhancement: MI	NEW EMIR MI: EMIR: Time: Hour Distribution	New graph in ‘Trading Time Bunching’ MI: displaying trends in execution, confirmation and clearing times.	TRD-71
12	Accuracy: EMIR	Fix: MI	EMIR MI Update: Reporting Firm breakdown	Amending the Summary MI to exclude Collateral reports from the high level counterparty view.	TRD-73
13	Accuracy: EMIR	Fix: MI	EMIR MI UPDATE: Collateral reporting methodology	Updating the MI to exclude Action type = K reports from summary.	TRD-72
14	Accuracy: EMIR	Delete: Validation	Delete E111	Deleting validation E111, as existing MI: ‘Trading time bunching’ is already displaying potentially hardcoded timestamps.	TRD-292
15	Accuracy: MiFIR	New Validation	New validation: M222 Investment Decision Within Firm not populated when client selling with discretionary mandate	Validation to check grouped orders where investment firm trading for its clients with a discretionary mandate has been reported correctly.	TRD-230
16	Accuracy: MiFIR	New Validation	New validation: M221 Investment Decision Within Firm: Not populated when client buying with discretionary mandate	Validation to check grouped orders where investment firm trading for its clients with a discretionary mandate has been reported correctly.	TRD-229
17	Accuracy: MiFIR	New Validation	New Validation: M224 Seller decision maker code (21) populated for a market side cpty	New MIFIR validation flagging where seller DM has been identified for a market side of transaction.	TRD-228
18	Accuracy: MiFIR	New Validation	New Validation: M223 Buyer decision maker code (12) populated for a market side cpty	New MIFIR validation flagging where seller DM has been identified for a market side of transaction.	TRD-227
19	Accuracy: MiFIR	New Validation	New validation: M220 Investment Decision Within Firm: Populated for INTC to market side	Validation to check grouped orders where investment firm trading for its clients with a discretionary mandate has been reported correctly.	TRD-226
20	Accuracy: MiFIR	New Validation	New validation M254 – Call option not matching CFI	A new validation which will identify a call option as identified in the instrument description field which doesn’t match the CFI code reported.	TRD-199
21	Accuracy: MiFIR	New Validation	New validation: M236 Short Sell Indicator populated for a derivative	TRA MIFID: New validation flagging “Short selling indicator” populated for derivatives	TRD-47
22	Accuracy: MiFIR	New Validation	New validations: MiFID M234/M235	TRA MIFID: 2 new validations checking correctness of “Country of the branch for the buyer/seller” against ISO3166.	TRD-44
23	Accuracy: MiFIR	New Validation	New Validation: M238 Seller decision maker code (21) not populated with Investment Manager ID	TRA MIFID: A new validation for reporting firms who provide a discretionary management service for their clients.	TRD-38
24	Accuracy: MiFIR	New Validation	New Validation: Buyer decision maker code (12) not populated with Investment Manager ID (M237)	TRA MIFID: A new validation for reporting firms who provide a discretionary management service for their clients.	TRD-39
25	Accuracy: MiFIR	Fix: Validation	M167 – Validation for Agency cross flagged for transfers	Amending validation to distinguish transfers from agency cross transactions and avoid flagging false positives.	TRD-271
26	Accuracy: MiFIR	Fix: Validation	Assume that individual = client (11 validations:M85, M86, M194, M196, M167, M18, M25, M38, M41, M44, M45)	We have re-defined how validations interpret Natural Persons. From now on, the NPs do not need to be added to Clients reference data (CRD_CL) for validations to assume they are on clients list. This allows to not input any sensitive information in CRD_CL and store it on the Portal, as well as reduces the need for frequent updates of the file for each Accuracy run	TRD-265
27	Accuracy: MiFIR	Fix: Validation	Bug: M3/M5 incorrectly flagging for joint accounts	Fixing a bug that causes incorrect flagging for joint account owners	TRD-264
28	Accuracy: MiFIR	Fix: Validation	M32 – correction for “commodity_underlying”	CN amending the logic to correctly recognise CFI codes of underlying commodity derivatives.	TRD-263
29	Accuracy: MiFIR	Fix: Validation	M41 – do not flag if related validations are already flagged	Added a condition to validation M41 to avoid double flagging by related validations.	TRD-236
30	Accuracy: MiFIR	Fix: Validation	M38 – do not flag if related validations are already flagged	Added a condition to validation M38 to avoid double flagging by related validations.	TRD-235
31	Accuracy: MiFIR	Fix: Validation	M83 – to become M83a and M83b	Splitting existing validation into 2: to highlight the cases where instrument was admitted to trading on the trading date	TRD-234
32	Accuracy: MiFIR	Fix: Validation	M60, M62, M124 – add clause to avoid double flagging	Amending 3 validations to avoid double flagging of the same issue by different validations.	TRD-43
33	Accuracy: MiFIR	Fix: Validation	M163 – add exceptions	Adding exceptions so validation does not flag for non-iso country code that is known to be used in ISINs	TRD-50
34	Accuracy: MiFIR	Fix: Validation	Update validation M21 – Price for spreadbets should be monetary value.	Update to our validation for the reporting of unit price type for spreadbets. Add a clause for where the underlying is an index.	TRD-45
35	Accuracy: MiFIR	Fix: Validation	correct validation M231 Quantity field validations for CFD	Validation updated to improve correct identification of CFD products.	TRD-40
36	Accuracy: MiFIR	Fix: Validation	M28 – validation update	Adjusting validation to flag for all instruments not admitted to trading irrespective of venue used.	TRD-46
37	Accuracy: MiFIR	Delete: Validation	M141 No ISIN for non EEA exchange – warning	Validation deleted – duplicating M140.	TRD-293
38	Accuracy: MiFIR	Delete: Validation	Delete M242	Validation deleted as entities registered as SIs may be still trading in a non-SI capacity.	TRD-279
39	Accuracy: MiFIR	Delete: Validation	Delete validation M162	TRA MIFID – validations deleted (duplicating other validations).	TRD-49
40	Accuracy: MiFIR	Delete: Validation	Delete M215 – SB/CFD: Underlying Currency doesn’t match LSE Listed Currency	We have deleted M215. It used to look at underlying products and check against our database of LSE listed products and return the currencies the product is listed in. A lot of LSE products are dual listed, so they are listed in other currencies, causing this validation to be triggered, when the record was valid. We have deleted this validation and will reimplement when we have a larger source of world wide listings.	TRD-42
41	Accuracy: MiFIR	Delete: Validation	Delete Validation: M13 – INTC has been used where “Trading capacity” is populated with ‘DEAL’.	Deleted a validation based upon guidance received by email from the FCA prior to MiFIR go live. CN no longer have access to the email and cannot support the validation from other Q&A’s/commentary – so deleting validation.	TRD-41

Please let us know if you have any questions: client.support@control-now.com.