Trade reporting

Immediate post-trade reporting is an obligation imposed by MiFID under Art. 28 is to be lovingly compared and contrasted with transaction reporting, an obligation imposed by MiFID under Art. 25.

A firm must make public specified information about transactions in shares admitted to trading on a regulated market outside a regulated market or MTF. Typically this must be done within 3 minutes of the transaction taking place. Deferred publication is however permitted for very large trades.

In a Nutshell™:

1. investment firms who execute, outside a regulated market or MTF, transactions in shares that are adminted to trading on a regulated market, must publish the volume and price of those transactions and the time at which they were concluded as close to real-time as possible, in a way which is easily accessible to other market participants. 2. This must happen in accordance with Article 45. Article 45's provisions allowing for deferred reporting for certain transaction types applies mutatis mutandis where those trades are undertaken outside regulated markets or MTFs. 3. The Commission shall:

(a) specify how investment firms may comply with their reporting obligations under paragraph 1 including:

(i) through the facilities of any regulated market MTF on which the share in question is traded;

(ii) through a third party;

(iii) through proprietary arrangements;

(b) clarify the application of the obligation under paragraph 1 to transactions involving the use of shares for collateral, lending or other purposes where the exchange of shares is determined by factors other than the current market valuation of the share.

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