MiFID I client data remediation and governance
The Financial Conduct Authority (FCA) issued a £4.7m fine to the client for failing to properly report 30 million transactions under MiFID I Directive. Axis was requested to lead the remediation and control work stream to close the audit point.
- Client had an outstanding audit point after being fined by the FCA for client counterparty misreporting.
- No systematic exception procedures in place, lack of data quality controls and operational risks identified.
- Poor governance model and stakeholder engagement.
- Low understanding of regulatory requirements and lack of training.
HOW WE HELPED
- Client reference data was prioritised and +95% of transactions reported to the national regulator (FCA) were remediated in the golden source and synchronised with the downstream systems.
- A robust Control Framework was designed, implemented and tested successfully.
- Business requirements were submitted in order to implement strategic solutions within the transaction reporting mechanisms.
- A new Governance Model was implemented, with clear responsibilities and roles.
- Audit point closed.
- Client reference data remediated.
- Operational risks mitigated.
- Control Framework successfully implemented.
- New governance model successfully implemented.