With all our recent focus on whether REMIT transaction reports are getting to the regulator at all, even with a T+1 reporting mandate, it is easy to loose sight of the importance of the relevant timestamps of orders, executions, and lifecycle events.
MiFIDII is very explicit on the subject, RTS 25 states:
“Competent authorities need to be able to reconstruct all events …… over multiple trading venues on a consolidated level to be able to conduct effective cross-venue monitoring on market abuse.”
This requirement is no less true of REMIT, which hands ACER the challenge of consolidating EMIR, REMIT and MiFID transaction reports from various venues and intermediaries. According to Tabb Group a ‘major European trading venue’ had to jump 30 seconds a few years back. Imagine today how many revised transaction reports that might entail today? This is one area where things could get worse if MiFIDII really is delayed!
It might be worth checking your own infrastructure and also RRM service level agreements include timestamp accuracy tolerances.