Regulatory Trade Reporting
The current regulatory climate and increased scrutiny of trading practices has significantly impacted transaction reporting with expanded requirements for asset types, trade details and timeliness. New requirements are in effect or being implemented in the US, the EU under EMIR, Canada, Japan, Hong Kong, Singapore, Australia, and by other regulatory bodies. The complexity and scope of implementing these rules internally has become prohibitively expensive. Bringing in outside expertise and third party solutions can speed compliance adoption at a lower cost.
For most firms, the incremental adjustments to compliance and reporting systems made over the years to accommodate ever increasing regulatory demands, coupled internally with the addition of new business lines in various regions, have resulted in compliance reporting systems that are piecemeal, disjointed, and in some areas, non-compliant.
Keeping abreast of the shifting compliance landscape in the US through our affiliation with various industry groups and relationships with regulators, Jordan & Jordan is acutely aware of changes in trade reporting rules and regulations. Leverage our knowledge to validate completeness and accuracy of information in your current processing and to ensure timeliness of reporting for the following:
- Order Audit Trail System (OATS) -Testing and verification is done for OATS submissions, and includes a comparison of a firm’s order and trade data to their Reportable Order Events (ROEs) located within the submission files used for OATS reporting to FINRA. This will include a review of the types of reports submitted (New Order, Route, Execution, Cancel, Combined reports etc.), to ensure that all ROEs the firm is responsible for, are included in their reporting to FINRA. A review will also be conducted for orders rejected by FINRA to verify that the firm is repairing the orders in a timely manner, and maintaining all supporting documentation associated with the rejection.
- Electronic Blue Sheets (EBS) - our review includes testing and comparison of trading records to the EBS reports to ensure all required activity is reported with all relevant fields populated correctly. We also provide guidance and recommendations to ensure that the firm's processes for updates or changes to the EBS process are successfully implemented.
- Trade Reporting and Compliance Engine (TRACE)
- Municipal Securities Rule Making Board (MSRB)
- OTC Derivatives reporting to a Swaps Data Repository (SDR)
- Data Validation Tools – J&J can spot-check your reports to ensure they adhere to industry specifications. Using our proprietary software, we can identify any formatting issues or deviations from ISG’s record layout for EBS reports and FINRA’s record layout for OATS.
While still not implemented, it is important to keep up-to-date on Consolidated Audit Trail (CAT) and Comprehensive Automated Risk Data System (CARDS) to determine how they could potentially impact your firm’s reporting requirements.
Jordan & Jordan’s trade reporting expertise leverages knowledge gained from our industry leadership and involvement working with regulators to shape requirements, and from our experience assisting broker-dealers with implementations. We can help you with an assessment of your current processes and procedures, or, we can assist in gathering and documenting the business requirements for new or enhanced systems. Whether you need a gap analysis and recommendations for improvement, require an impact analysis, or support for a new implementation, Jordan & Jordan’s subject matter experts will draw from their years of experience in order and trade processing, data management and reporting to solidify your regulatory reporting program.
- Jordan & Jordan has provided a number of clients with a comprehensive review of the processes and technologies that support their regulatory reporting requirements including those directed by the Financial Industry Regulatory Authority (FINRA) using the Order Audit Trail System (OATS) for all NMS securities; the Trade Reporting and Compliance Engine (TRACE) for corporates, agency debt, and asset backed securities; and the Municipal Securities Rule Making Board (MSRB) using the Real Time Reporting System (RTRS) for municipal bonds.
- For large, retail and institutional brokerage firms, Jordan & Jordan has conducted complete assessments of their Electronic Blue Sheets (EBS) reporting processes. This included a review of manual processes and touch points for handling EBS requests, automated formatting checks and extensive comparisons of order/trade records to EBS data to ensure all transactions are reported accurately. Jordan & Jordan paid particular attention to the software development lifecycle (SDLC), resulting in improvements to technology release management controls.