Project Overview
A UK FCA-authorised asset management firm with £8.4B AUM and 12 different FCA regulatory reports (MiFID II tra...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised asset management firm with £8.4B AUM and 12 different FCA regulatory reports (MiFID II transaction reporting, AIFMD Annex IV, EMIR trade reporting, COLL fund reporting, COBS suitability records) needed to automate their regulatory reporting — replacing a manual process that cost 3.2 FTE and took an average of 4.8 days per report. FCA EMIR Reporting (SFTR from 2024), MiFID II Transaction Reporting (ARM — Approved Reporting Mechanism), AIFMD data reporting to FCA, and COLL fund administration reporting were the primary technical requirements. Budget: £130,000.
Our Approach
MiFID II Article 26
investment firms must report all transactions to the FCA via an ARM (Approved Reporting Mechanism) on T+1.
ARM integration
UnaVista (LSEG) ARM API — transaction submission (ISO 20022 format), rejection management (rejected transactions must be resubmitted within 3 working days), and reconciliation report (submitted vs FCA confirmed).
Transaction data pipeline
- OMS (Bloomberg AIM or SS&
- C Eze) → normalisation (counterparty LEI lookup, instrument ISIN/MIC mapping) → MiFID II XML generation → UnaVista ARM submission.
Rejection rate target
- <
- 0.5%.
EMIR SFTR Reporting
SFTR (Securities Financing Transactions Regulation — UK retained post-Brexit): repos, securities lending, margin loans reported to trade repository (DTCC or Regis-TR).
SFTR report
- 155 fields per transaction (UTI, collateral details, counterparty LEI, maturity date).
- UTI (Unique Transaction Identifier) generation: waterfall — counterparty UTI if available, otherwise generate and share.
SFTR data pipeline
Prime Broker data (repo/stock lending positions) → UTI matching → SFTR XML generation → Trade Repository API submission.
UK FCA SFTR
UK version post-Brexit (FCA UTI prefix UK).
AIFMD Annex IV
Alternative Investment Fund Managers must submit a detailed portfolio report to FCA quarterly/semi-annually/annually depending on AUM. 300+ data fields: fund NAV, leverage, liquidity risk metrics, counterparty exposures, investor concentration.
Data pipeline
- fund accounting system (SS&
- C Geneva or SimCorp Dimension) → AIFMD Annex IV XML → FCA Gabriel (FCA reporting portal) submission via XBRL taxonomy.
FCA Gabriel API
AIFMD submission, acknowledgement, and error correction workflow.
Master regulatory reporting dashboard
status of all 12 regulatory reports (submitted/pending/rejected/overdue), submission history, FCA acknowledgement status, and upcoming report deadlines (calendar view with 10-working-day advance alerts).
Reconciliation
automated cross-report consistency checks (MiFID II transaction data consistent with COBS suitability records, AIFMD portfolio data consistent with fund accounting).
Exception management
regulatory data exceptions flagged to compliance team with resolution deadline and FCA submission deadline countdown.
The Results
Platform live at 22 weeks, £120,000 — under budget.
MiFID II rejection rate: 3.2% → 0.3% (automated field validation catches errors before submission).
AIFMD Annex IV: first fully automated submission — previously 4.8 days manual.
SFTR UTI reconciliation: 99.6% automated (0.4% manual exceptions — complex repo structures).
Regulatory reporting FTE: 3.2 → 0.8 FTE (75% cost reduction — £240,000 annual saving).
Zero regulatory reporting breaches (late submission) in first 12 months.
FCA supervisory visit: zero reportable findings on reporting processes.
“3.2 FTE to 0.8 FTE — £240,000 annual saving. MiFID II rejection rate from 3.2% to 0.3%. SFTR 99.6% automated. Zero late submissions in 12 months — for a £8.4 billion AUM manager, a late regulatory report is a material event. FCA supervisory visit with zero findings on our reporting processes. The compliance team now spends their time on compliance judgment, not data entry." — Chief Compliance Officer, UK Asset Manager (name withheld)”
Project Details
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