MiFID II

Customer Oversight

The Siena Contact Manager supports MiFID II Customer Oversight requirements in full and provides a central overview of your customers. Siena's Contact Manager ties together all the communications and resulting quotes and deals transacted for a customer. By bringing together these existing functions, the Siena Contact Manager delivers a central overview of your customers and the individuals/organisations mandated to act on their behalf.

Appropriateness & Control

Siena’s highly flexible business rules include pre-deal credit checking, latency controls, profit checking and fat finger protections. Its highly configurable customer controls include trading channel, amount bands, instrument and asset class permissioning. In addition, Siena provides real-time connectivity to existing AML & KYC systems.

Pre-Trade Compliance

Siena provides up-front information, warnings and reports in line with MiFID II Pre-Trade Compliance requirements, including transparency, best execution warnings, latency reporting and waivers:

• Siena is ready to stream any price or rate for any instrument to any number of venues both internal to the bank and externally to MTFs to provide full pricing transparency.
• Best Execution alerts are triggered when a customer attempts to trade on a price that is beyond the acceptable tolerance range when compared against a prevailing market-neutral benchmark mid-rate.
• Best Execution data, currency benchmark rates etc. are stored with every order and deal, market neutral benchmarks are acquired using ready-to-deploy adaptors to providers.
• Latency Reporting is available to highlight any latency issues and price variances between quote and final execution.

Record Keeping & Telephony

Siena captures all customer communications, whether it be through phone conversations, email or online trading platforms. All actions across quotes, orders and deals are UTC time-stamped and associated with the relevant Siena user. This enables sales traders to get on with the business of the day, knowing their activities are transparent.

Trade & Order Handling

Siena accepts real-time feeds from external systems. When connected to external systems Siena can operate in a primary or secondary role for specific instruments and the order workflow can be driven either by Siena or the external system. All messages can be configured to ACK/NACK with external systems to ensure message synchronisation. If your organisation uses a message hub, the software can monitor the hub for transactions and process them. Siena adaptors allow for the normalisation of trade and order data and from all order, trading and messaging platforms into one common format for storage, reporting and processing.

Post-Trade Disclosure

Siena supports the MiFID II Post Trade Disclosure requirement for non-equity deals to be available within 15 minutes. This figure will reduce to 5 minutes in 2020. To support regulatory reporting and investigation requirements Siena captures and reports;

• Customer segmentation
• Instrument taxonomy
• Trade Reconstruction
• Best Execution
• Pre and post-execution rate/quote latency
• Venue latency statistics
• Fully traceable dealer chat
• All trading related communications

To assess the market impact of trading activity post-trade benchmarks are recorded at pre-set intervals or your custom range following the order and trade execution. At any time a deal and its full history can be presented to users, as can a full Trade Reconstruction report.

All relevant data will be available for a definable period of time - typically 7 years.

Best Execution

Siena supports MiFID II best execution policy by ensuring benchmark rates, prices and volatilities are recorded on all deals and orders across all instrument classes based on the user-definable benchmark source. Additionally, benchmarking data is stored against each deal/order for all lifecycle events including but not limited to Option Exercise, Assignment & Expiry and Order actions.

Details of all costs and charges incurred on a deal by the counterparty are recorded and available in Siena, alongside the default values for these. All costs/charges and fees are reportable in the regulatory reporting currency. The margins applied to the deal are available in Siena along with all the default margins that would have applied at the point of execution/exercise.

Customer Reporting

Siena supports MiFID II customer reporting requirements. These include data such as LEIs and other forms of ID including Passport Number, Country/Jurisdiction, First Name(s), Surname(s), DOB, Country, Post Code and National ID Number. All this data can be used in customer reporting to identify the customer and generate a UTI from the LEI or any of the other unique identifies if the LEI is not available.

Market Data Reporting

Siena holds data that can be reported on for each of the categories required and optionally generate Term Sheets. All deals & instruments are automatically assigned ISINs. Siena provides MiFID II regulatory reporting support for any number of other deals/order types using its customisable templates.

Trade Reporting

Siena’s real-time deal capture and reporting engine effortlessly satisfy the need to report post-trade pricing and other transparency details into an approved APA. In addition, Siena allows reporting segregation whereby information for different instruments or asset classes can be fed to separate destinations.

Transaction Reporting

Siena’s ready-to-deploy adaptors provide connections to ARM's such as UnaVista, NEX and TRAX. Siena adaptors provide multiple ways to submit trade records to the repository service to provide maximum flexibility based on technology and volume consideration. Order and Trade reporting waivers are supported for all customer, deal and order types - including block trades - and are enacted during reporting.

Systemic Internalisation

Siena empowers compliance teams to monitor your SI status by allowing reporting over at least 6 months of trading activity from all connected venues.
Siena supports;

• SI status monitoring data
• Comprehensive pre-trade transparency
• Term Sheet generation data
• Best execution
• Waivers
• Latency reporting