Who have we created Cesarz_MiFIR for?
This module of the Cesarz system has been designed to fulfill the requirements of the MiFID II MiFIR regulations, which extend the obligation to report financial market transactions to the Polish Financial Supervision Authority.
The module is designed for implementation at such investment entities as banks, brokerage houses, or custodians. The reporting of events concerning securities and derivative transactions to a regulator takes place in a new way, in comparison to the MiFID I Directive. It includes, to a great degree, information which has not been collected so far (e.g. the so-called “decision maker”), information with characteristics different than those in other reports (e.g. EMIR), and a new data format.
The changes which are being made concern brokerage and banking activity, which leads to modifications in the IT systems used by the treasury and custody departments, as well as by brokerage offices/houses. The scope of the reported data is about a dozen times greater (more transaction types, complicated exceptions, various types of contracts dedicated to various entities, the possibility of reporting on behalf of a third party, more fields, events accompanying a transaction, a different data format).
New areas will be included in the requirement, for example, custody, which means that reporting will now include, among other things, the transfer of securities between client accounts.
Taking into account the ESMA guidelines, the Cesarz_MiFIR software will allow for reporting to the supervisor in a non-redundant manner and without repetitions, including: the testing of the reporting process, reconciliation with the data samples from the Polish Financial Supervision Authority, completeness, exclusion of errors, agreement with the actual state of affairs, timeliness, and transparency before and after transactions.
Taking into account that reporting is one of the dozen or so important requirements of MiFID II/MiFIR, which have an influence on IT systems, and that those requirements are interrelated, the scope and degree of the complexity of regulatory projects to be realized in 2017 are exceptionally big. Very soon there will be, in the same areas of banking, an obligation to implement EMIR II, SFTR, or PRIIPS.