Zach Johnson Featured in Thomson Reuters: ISIN-Related Transaction Reporting Rejections Create Another MiFID II Headache

Zach Johnson, Director in Duff & Phelps’ Compliance and Regulatory Consulting practice, was featured in Thomson Reuters discussing how firms required to transaction report under the Markets in Financial Instruments Directive II have to manage a growing pool of reports rejected by regulators, which firms still believe are reportable. These rejections occur because the International Securities Identification Number (ISIN) does not appear in the European Securities and Markets Authority (ESMA) database. ESMA created its Financial Instrument Reference Data System (FIRDS) as a daily-updated database of ISINs for all transactions executed. Regulators do expect firms to submit reports for transactions even if the ISIN does not appear in FIRDS.

"There will be firms that go the extra mile and use multiple sources to identify reportable transactions. In some instances, the instrument won't appear in FIRDS because it has not been provided by the trading venue or it appears several days later, as there can be a time lag. Where the instrument doesn't appear in FIRDS, firms should raise such cases with their regulator or their authorized reporting mechanism [ARM]", said Zach

Read the full article in Thomson Reuters