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Case Studies

Case Study

Market Infrastructure Remediation

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SUMMARY

Following the strategic decision to move the European headquarters from one Member state to another, the Bank decided to review and re-evaluate its compliance with the MiFIR/EMIR regulatory requirements. Several gaps were identified which required immediate remediation before going under the supervision of a new national competent authority. Avantage Reply was chosen to support the Bank in the remediation efforts.

CUSTOMER GOALS

The Bank’s Market Infrastructure team required assistance with several issues related to data quality and transaction reporting, risk and control framework and other compliance obligations. The primary goals were the following:

  • Remediate the EMIR/MiFIR transaction reporting gaps (i.e., Post-Trade Transparency and Transactional Reporting etc.)
  • Remediate record-keeping gaps
  • Remediate data quality gaps (i.e., timestamps, missing LEIs, incorrect UTIs etc.)
  • Assist other internal teams in the remediation of many more gaps related to trading and transaction reporting

CHALLENGES

The primary challenge was that a diverse list of gaps with several complexity levels had to be all remediated within a relatively short period of time (6-7 months). Considering that most of the projects involved IT and Regulatory experts meant that the same teams were working on multiple gaps at the same time which put additional pressure on the resources.

SOLUTIONS

Avantage Reply provided several full-time resources who led the overall project management activities for all gaps and informed the project stakeholders on the overall progress while at the same providing technical and regulatory expertise to help address specific elements related to EMIR and MiFIR regulatory requirements.

The final delivery consisted of:

  • Project management deliverables (i.e., status updates, meeting minutes, budget estimations, relevant committees’ presentations etc.)
  • Business analysis of the trading set-up and the impact from the regulation (i.e., workflow maps and business requirements)
  • Technical analysis of the required changes in the IT infrastructure

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