NetfolioMiFIR

Automated reporting of transactions with financial instruments

From 2018, the ‘Markets in Financial Instruments Regulation’ (MiFIR) will require investment firms based in the EU or EEA to report transactions with financial instruments. To comply with this new regulation, Alphasys has developed a secure interface for independent asset managers or financial intermediaries (FIMs).

NetfolioMiFIR enriches the data (which are either sent electronically or entered manually) with MiFIR-related data and forwards them directly or via an ARM (Approved Reporting Mechanism) such as UnaVista to the regulator. Delivery via ARM is only possible if the FIM has an account.

Currently the delivery to the following regulators is possible:

AFM (Netherlands)
BaFIN (Germany)
CySEC (Cyprus)
Central Bank of Ireland
FMA (Liechtenstein)

ARM (Approved Reporting Mechanism)

Athex (Greece)
UnaVista (London)

NetfolioMiFIR provides

legally compliant reporting to the regulator
automated data enrichment with transaction data
Reports are sent via file upload, NetfolioMiFIR’s web service or ARM to the regulator, for instance to the Financial Market Authority of Liechtenstein (FMA) or German Financial Supervisory Authority (BaFin)
the FIM retains data sovereignty

Delivery to the regulator

Once the transaction data has been enriched for the regulator and has been approved, they can be sent to the regulator. There are a few options for delivery:

1. Direct delivery of the data to the regulator via an automated interface.
The system is designed to enable fully automated delivery (no action by the FIM is required). This option must be requested specifically. The FIM remains responsible for the data contents. If the system identifies an error, the FIM must correct it manually.
2. In compliance with ESMA guidelines, download a spreadsheet (Excel file in CSV format) to the computer of the independent asset manager: Direct delivery to the regulator or forwarding via ARM.

Interface for portfolio management systems

Many portfolio management systems (PMS) do not yet have a reporting function for MiFIR transaction reports. Alphasys has developed the NetfolioMiFIR interface for delivering banking data electronically and using default controls to enrich the data with the data required by law. If there are alterations to the requirements, these data can be mutated.

For NetfolioMiFIR, Alphasys provides the FIM with a dedicated environment. If the transaction data is sent to one of the FIM’s servers, it must be forwarded to Alphasys via web service or SFTP. For cases in which bank transaction data is not downloaded onto local servers, Alphasys provides EBICS software developed specifically for this purpose.For FIMs without PMS, Alphasys recommends enriching the transactions with NetfolioMiFIR on a virtual server and then forwarding them to the regulator.

Simple MiFIR data enrichment

According to the MiFIR, transaction reports must be sent to the regulator by the end of the next working day (Art. 26 of Regulation (EU) No. 600/2014 dated 15 May 2014). Some banks, such as UBS, provide transaction data to the asset managers electronically. To complete MiFIR reporting, this data must be enriched with information that only the FIM can access.

Cost-efficient solution

NetfolioMiFIR is available as a built-in addon to the asset management solution Netfolio. For FIM without IT infrastructure or the proper software, we can provide NetfolioMiFIR as a service starting at CHF 100 per month. The contract for using the interface is made with Alphasys AG. The data is hosted securely in Switzerland or by the Netfolio customers themselves. Data protection and security have the highest priority and are guaranteed.