Transaction Reporting System MiFID FAQs

We are required to implement the European Markets in Financial Instruments Directive (MiFID) by 5 November 2007. One of the significant changes MiFID imposes affects the regime governing transaction reporting (currently administered under Chapter 17 of the FSA Handbook Supervision Manual).

In particular, MiFID requires us to approve each reporting system (to be known as an Approved Reporting Mechanism or ARM) that is not an exchange, or a multilateral trading facility (MTF), wishing to offer a transaction reporting service to us. To ensure that all transaction reporting systems firms use to submit transaction reports to us comply with the requirements imposed by MiFID, we intend to impose the same criteria on all prospective ARM applicants. Consequently, TRS must undergo the ARM approval process and follow the ARM technical specifications (for further information please see the ARMs section of our website).

On 25 May 2007, we granted TRS conditional approval to become an ARM and to submit transaction reports on behalf of firms after MiFID implementation on 5 November 2007. The conditional approval is subject to successful testing of TRS's IT systems. We will announce full approval for ARMs no later than 12 October 2007; however, we hope to obtain approval before that date.

Certain changes are being made to TRS in line with the ARM's technical specifications and supporting documents. This will allow firms to report to us in line with the new SUP 17 once MiFID is implemented (for further information please see FSA Policy Statement 07/2.

We have updated the following technical documents in order to submit transaction reports to TRS in line with the new SUP 17:

• TRS (Markets) Data Reference Guide version 4-0;
• TRS System to System Interface Guide version 3-0; and;
• XML Markets Data Schema version 1-1.

We have sent an email containing the full set of TRS XML Schemas and Reference Guides, including those updated technical documents listed above, to all Primary Contacts at each TRS markets firm. If you wish to receive this email, please contact the TRS Service Desk (managed on our behalf by LogicaCMG) on 0870 0130 467, quoting your FSA reference number.

The updated TRS Markets Data Schema completely replaces the existing Markets Data Schema before 5 November 2007. From 5 November 2007, TRS will no longer be able to accept transaction reports submitted to it based on the the existing Schema or altered versions of it.

Please note that the XML Schemas and Reference Guides are only relevant to firms who intend to submit transaction reports via the web upload and system-to-system methods. We intend to update the web form for entering transaction reports manually online for both the TRS Trial Application and TRS Main Application.

We are currently updating the TRS Trial Application (the test environment) and testing our internal systems. Once we have done this, we will open the TRS Trial Application from 3 October 2007 for you to test submitting MiFID compliant transaction reports.

You may submit test data into the TRS Trial Application as often as you like, using all three methods, ie manually keying reports into the web form, web upload and system to system.

All TRS Primary Contacts should have a valid UserId and Password to log in to the TRS Trial Application. Please note that the UserId and Password is different to the one you use to log in to the TRS Main Application. If you have forgotten your UserId and Password for the TRS Trial Application please contact the TRS Service Desk (managed on our behalf by LogicaCMG) on 0870 0130 467, quoting your FSA reference number.

Yes. Once testing has been completed, the TRS Trial Application will be opened for all other markets firms to test and re-certify. Those firms wishing to submit transaction reports via web upload and system-to-system methods (i.e. using the new XML Schema) will have to re-certify via the updated TRS Trial Application. This involves the same process as when you originally certified, that is:

• you conduct your testing in the updated TRS Trial Application and confirm your ability to submit a correctly formed XML schema using the new Markets Data Schema (version 1-1);
• when you are ready to re-certify, contact the TRS Service Desk, quoting your FSA reference number, and tell us that you have submitted a transaction report which requires checking for re-certification purposes; and
• the TRS Service Desk will review the transaction report and advise whether you have successfully re-certified.

The TRS Service Desk will keep a register of all those firms that have successfully re-certified in order to submit transaction reports into the 'TRS Main Application' via web upload and system-to-system methods from 5 November 2007.

Yes. Please re-certify in line with the following timetable so we can manage the large number of firms wishing to re-certify. You are welcome to re-certify before your allocated date if you are able to do so.

We have set aside the period between 24 October to 5 November 2007 for contingency purposes. So firms will have an opportunity to resolve any outstanding issues arising from testing and re-certification before 5 November 2007.

If you are manually keying reports into the web form, you do not need to re-certify. However, please satisfy yourself that you are able to use the new screen layout and you are able to successfully submit MiFID compliant transaction reports before 5 November 2007.