Market Watch 81 might on a first pass appear relatively uncontroversial in giving feedback on the FCA’s recent findings on transaction reporting. I would say that one should think again on this and suggest that there is a lot of food for thought here.
The basics on the Market Watch are set out in our earlier blog here.
I think that the really interesting points in the Market Watch relate to the depth of governance a firm needs to satisfy the FCA. I would pick up three points in this context all of which sit under what I would describe as the governance umbrella.
First, the importance of documentation. The old days in which firms might delegate most of this area to the technical IT transaction reporting specialists need to be over. The FCA’s messages on having adequate documentation, including in relation to change management, clarity about first- and second-line roles, escalation mechanics, adequate data lineage, escalation mechanics and MI are all clear. Firms need to review all o
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