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Clarifications in connection with the submission of reports by the investment intermediaries after the entry into force of the regulations which are part of the legal frame of MiFID II – 3.01.2018
Today is the date of entry into force of the regulations related to the implementation of the legal frame of the MiFID II, inclusively of the Regulation (EG) 600/2014 on the markets of financial instruments (MiFIR). According to Art. 26 of the latter, investment intermediaries who close transactions with financial instruments shall provide a complete and accurate report of them to the competent authority not later than the end of the next business day. A detailed information about the content of the report in question is included in Regulation (EC) №2017/590 supplementing Regulation (EU) №600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities.
Currently elaborates the FSC a new information system in order to launch the electronic mechanism for submission of the information due to Art.26 of MiFIR by both the investment intermediaries and the approved reporting mechanisms (ARMs). In connection with this matter, please pay attention to the following aspects:
- For the period between 03.01.2017 and the moment of starting the system, the FSC will accept reports composed by the investment intermediaries according to the regulations’ requirements per e-mail: email@example.com, similar to the mechanism for accepting the previous reports required under Art. 38 of the Markets in Financial Instruments Act;
- There is no granted option the ARMs to collect, validate and keep the reports of their clients supervised by the FSC, as well as to send the collected statements when the system is started because in the meantime the FSC is not going to receive reports for the respective supervised persons, i.e. it will accept the reports submitted by the ARMs via firstname.lastname@example.org, based on the contract agreed to the delegation of the responsibility in question;
- All news and updates concerning the new information system built up for the purpose of the operations described above and directly related to the reporting, according to the requirements of Art.26 of MiFIR, and taking into account the multiple questions put by foreign companies, will be published in English on the internet site of the FSC in due time.