The RTS hasn’t been finalised yet, so there’s no need to start thinking about it yet…right?
No…in all likelihood, transaction reporting under SFTR is going to be complex and a huge challenge, perhaps even more so than MiFIR transaction reporting. Whilst reporting obligations are not likely to start until Q4 2019, identifying which transactions need to be reported and what data is required to support those reports can, and probably should start now. Data quality will be key, and even though the final draft of the RTS is still a couple of months away, it is not too early to take some initial steps and start a gap analysis.