The European Securities and Markets Authority (ESMA) has published a consultation paper on draft guidelines on the application of its final draft regulatory technical standards (RTS) on transaction reporting, instrument reference data, order record keeping and clock synchronisation.
Specifically, the guidelines relate to RTS 22 (transaction reporting), 23 (instrument reference data), 24 (order record keeping) and 25 (clock synchronisation) which were published on 28 September 2015 in ESMA’s final report on draft regulatory and implementing technical standards under MiFID II and MiFIR.
The consultation paper is divided into three sections:
- section 1 specifies individual scenarios applicable to a given transaction reporting activity;
- section 2 specifies scenarios applicable to specific order record keeping activities; and
- section 3 provides clarifications on the application of the clock synchronisation requirements.
The deadline for comments on the consultation paper is 23 March 2016. ESMA will consider the feedback in Q2 2016 and expects to publish the final guidelines in the second half of 2016.