RTS 13: Organisational Requirements for Data Service Reporting Providers
Bats currently operates a Trade Data Monitor (TDM) and is on the official list maintained by the FCA. Under MiFID II, Bats intends to operate an Approved Publication Arrangement (APA) under our Recognised Investment Exchange status.
Bats will need to formally apply to the FCA for the APA designation in advance of the effective date of MiFID II. At the current time the FCA has not indicated what the timetable is for processing DRSP applications. However, it has a statutory obligation to deal with applications within a 6 month timeframe.
As part of any application Bats will need to demonstrate how it meets the requirements in RTS13 regarding the following areas:
- Its organisational structure
- Corporate governance
- Management structure
- Preventing conflicts of interests
- Business continuity and backup
- Managing incomplete or potentially erroneous information
Current or prospective users of the Bats APA services should note that the current TDM Service is audited annually against very similar standards.
MiFID II requires data to be published in a machine readable format. Bats data formats meet required standards of machine readability, except for one area within BXTR where Bats allows the reporting of trades in symbols unknown to us for Over the Counter trades or trades conducted on third-party MTFs. These are currently published here. To meet the machine readability requirements, and customers' requests, Bats intends to start publishing such trades on our data feeds. Thereafter the web page will be decommissioned.
Use of the APA service will be conditional on firms ensuring they do not submit duplicate trade reports.