Information
Management Challenges
Lifecycle  Perhaps
one of the most critical data management challenges
presented by MiFID, is information lifecycle.
Under the record keeping and reporting provisions,
firms will be responsible for making available
records of all financial instrument transactions
to the regulatory authority in a timely manner.
As the MiFID
Readiness Survey concludes "storing best
execution data is one thing, reconstituting it
for audit purposes is another". Reconstituting
it with context and history to prove best execution
as the result of a challenge up to five years
after the event is going to be hard - particularly
if the requirement becomes part of an auditable
compliance process.
Under the best execution provisions,
a reconstituted trade may comprise information
sourced from multiple heterogeneous systems each
with their independent data archiving policies
(80% of firms surveyed by the MiFID JWG claimed
that data required to support best execution obligations
were not on unified systems). During the interval
between the transaction and the audit for proof,
underlying data schemas such as instrument identifiers
for the monitored best execution venues might
have changed.
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