The detail

This international investment bank had discovered they were not fully compliant with the trade and transaction reporting requirements of MiFID. After hiring another consultancy to work on the project, the bank was not confident that all the issues had been identified or that they would fully resolve their problems. So, they gave us a call...

Are you fully MiFID compliant? This international investment bank discovered they weren’t. So they engaged us to fix things…

Outcome

Full sustainable regulatory compliance, demonstrable to the regulator & with ongoing senior management visibility / oversight.

Method

Detailed analysis, fix definition & project management to completion.

This international investment bank had discovered they were not fully compliant with the trade and transaction reporting requirements of MiFID. On realising this, they engaged another consulting firm to clarify their obligations and identify the actions needed to resolve the issues. But, by the end, the bank was not confident that all the issues had been identified or that they would fully resolve their problems. So, they got in touch with us…

Why Elixirr?

We had previously worked with this bank on numerous other engagements, so they knew us and the quality of our delivery well. They were confident that we could restore compliance for them because of our thorough, appropriate analysis and remediation method. And we didn’t disappoint.

The challenge

“Help make us compliant”, they challenged us. We needed to tell them exactly what their obligations were, and to what extent they were already meeting them.

The approach

We began by reviewing the existing work. Once the gaps were identified alongside any material non-compliance, we highlighted the highest priority areas for investigation.

We analysed trade data to understand what the reportable population should have been and compared it to the population that was reported. Through this, we were able to identify under- and over-reporting populations.

Further front-to-back, field-by-field analysis was needed to compare transaction reports to their underlying source data in both front and back office systems. This allowed us to identify errors and process failures. These failures were investigated with technical and operational users to understand the root causes, and identify the remediation actions required.

Finally, we defined and implemented a robust governance framework to ensure continued compliance with MiFID.

The value

We fully defined what this bank was required to do and all recommended fixes have subsequently been implemented. Once the identified issues are all resolved, this bank will be fully compliant with MiFID. To support this bank in ensuring that the fixes remain permanent, we defined and implemented an ongoing governance plan.

The praise

"I would not hesitate to hire Elixirr again: we’re looking forward to continuing our partnership with them well into the future.”

Chief Operating Officer