MIFIR

General Introduction

The MIFIR reporting obligations will come into force very soon. This page has been create to help you to find the right answers to your questions. If not otherwise indicated, Fundsquare has answered to those questions. Should we as a official transmission channel obtain information from the regulatory body, we will indicate this accordingly.

Timeline

Date	Action
2 January 2018	last possible trade date for previous MiFID I transaction reporting
3 January 2018	MiFIR enters into force
31 January 2018	End of parallel run periode (where corrections and late declarations for trade dates equal and older than 2 January 2018 are accepted in the old format

Transition period

In order to ensure a smooth transition from the MiFID I regime to the new MiFID II/MiFIR regime, CSSF will operate both the new and the old transaction reporting systems in parallel until 31 January 2018.
It must be noted that the old system will reject any transaction report referring to a trading date after 2 January 2018, since the parallel run is only intended to allow for late declarations and error corrections of transactions executed prior to the entry into force date of MiFIR.
After 31 January 2018, the MiFID I transaction reporting system will be decommissioned.

Useful documentation

• The communciation of the CSSF on this topic provides already a good overview on the different topics of interest and contains many useful links.
• The selection of additional documents on this topic on the website CSSF provides further insight.
• The XML schemas (XSD) can be found here. [1]

Frequently asked Questions

As an official transmission channel to this reporting type, we will list all the questions we have obtained from our clients and the information we are able to provide either based on the available information or as the CSSF has provided us with a feedback (where indicated)

Question	Fundsquare's statement
Required file format	XML file according to ESMA's specifications
Maximum file size	The regulator currently fixed the limit to 60MB per file, but this is subject to change
Maximum records per file	no limit is known for the moment, the file size is the sole known limit
File naming convention	Pending final validation, it is our current understanding that the naming convention of MIFID I reporting will be applied as outlined in the CSSF press release 16/43.
Header Information	The information can be found on page 41 of this document [[2]]
Business message identifier details	The information can be found on page 41 of this [[3]]
File feedback message details	The information can be found on page 27 of this [[4]]
Does the feedback message will contain personal information	The file will contain trasnaction information as per XSD
Limits to the number of submissions each day	The file must contain all transactions of the day.
Submission cut-off time	All transactions of a given day must be provided in the file of a given day
How is the transmission of the file to the authority organized?	Fundsquare expects its clients to use the sending service to perform the submission of this reporting. It is directly transmitted to the authority once the sending service has handled the file.
What are the different status of the transmission of the document between the client and Fundsquare?	If not otherwise noted, it is foreseen to keep the same type of processing on the sending service as we apply for other types of reporting of the same kind limited to the use of the sending service. (.trt, .acq, ...). Other status may apply but are not known at this point of time.