Reporting as an SYSC issue: Establishing governance maps for transaction reporting

Abstract

Financial services regulatory reporting encompasses many different types of reports made by a variety of regulated entities. This paper focuses on transaction reporting by financial firms, an area that has seen significant Financial Conduct Authority (FCA) fines in recent years. It provides the background to governance arrangements in the context of transaction reporting and recommends that firms implement functional governance maps for transaction reporting in line with existing and proposed FCA requirements, given the complexity of overseeing and ensuring accuracy in reports and in light of competing regulatory obligations in the area of regulatory reporting. The paper also provides rudimentary governance maps in the context of transaction reporting as examples of arrangements that can be visually represented in firms’ existing policies. Finally, the paper makes three practical recommendations for firms to improve their governance arrangements in the context of transaction reporting.