Do the APM Guidelines require a numeric reconciliation of the APM to “the most reconcilable line item, total or subtotal” presented in the financial statements or is it sufficient to include a qualitative explanation of the items which adjust the financial statement’s figures?

Are securities financing transactions (SFTs) in scope of the MiFID II requirements for order record keeping, as outlined in Article 16(6) of MiFID II and further specified in Section 8 of the MiFID II Delegated Regulation?

Pursuant to Article 13 of SFTR, UCITS management companies, UCITS investment companies, and AIFMs (“UCITS/AIF managers”) shall inform investors on the use they make of SFTs and total return swaps in annual (UCITS and AIFs) and half-yearly (UCITS only) reports. The information on SFTs and total return swaps shall include the data provided for in Section A of the Annex to SFTR.

Should this data be reported as aggregate data (with respect to the whole of the reporting period) or based on a snapshot (taken at the end of the reporting period)?

(a) How to complete reference data and transaction reports for financial instruments with a fixed rate that is a volatile attribute.
(b) How to complete reference data and transaction reports for financial instruments with a strike price that is a volatile attribute.

Consider a scenario where an investment firm (Bank B) executes a reportable transaction under a discretionary mandate for a Client A (portfolio management).

a) Does the Client A also have an obligation to report this transaction under Art. 26 MiFIR?
b) Does the Client A also have an obligation to report this transaction under Art. 26 MiFIR when a fund management company that is not a MiFID II investment firm (Firm Z) is interposing between client and Bank B?