The document outlines Point Nine's trade and transaction reporting services, highlighting features such as automated solutions, error resolution processes, and data validations. It emphasizes the platform's capabilities in reconciliation, error management, and compliance with regulatory requirements, aiming to improve transaction reporting transparency and accuracy. The document also mentions significant regulatory fines for reporting failures by various financial institutions, underscoring the importance of compliance in transaction reporting.

1. www.p9dt.com
Trade & Transaction
reporting Services

2. Contents
2
• Solution Overview
• Onboarding
• Reporting
• Error Resolution
• Reconciliation
• Client Portal & Email Reports
• Validations
• Reporting Fines
Powered and Secured By: Developed In:

3. 3
Reporting as a Service
Solution Overview

4. 4
Point Nine Solution And
Benefits 1/2
• Cross Asset & Contract
Coverage
Options / CFDs/ Warrants/ Commodities
etc
• Premier 9 Reporting
Platform
P9 proprietary technology
• Reconciliation Engine
Multiple Sources Pairing / Matching
• UTI Management
Generation / Shadow / Sharing
• Data Mapping &
Enrichment
FIRDS, FIS Global, Bloomberg
Symbology, ANNA-DSB
• Validation Engine
P9, ESMA/FCA, TR/ARM/NCA, Customers
• Fully Automated Solution
Take the pain away
● Connectivity
SFTP, S3, Database, Email
To Trade Repos, and/or ARMs
• Flexibility
Bespoke validation and business
rules
• Conversions
As per NCAs / TRs / ARMs reporting
requirements
• Amazon & AWS
Workspaces
Reliable Encryption & Security
• Python & ETL
Complex Data Management,
Performance
Solution Overview

5. 5
Point Nine Solution And
Benefits 2/2
• ISIN Eligibility
Instrument routing
• Job Based Solution
ID for Easy Communication
• Full Scope Reporting
Trade/position/valuation/collateral
reporting
• Full Audit Trail
Accepted / Pending / Rejected Records
• Email Notification &
Portal Access
Accepted / Pending / Rejected Records
TR reconciliation state (matched,
unmatched, paired, unpaired )
Trade blotter (query specific transactions
by UTI, TR state, Counterparty Id, Action)
Exception / Data Quality Management
• Exception /Data Quality
Management
Transparency
• State Machine
Historical Trade Statuses
• Lifecycle Events
Support Corporate Actions
• Replay Features
Replay pending records
• CFI Management
Validation and Construction
• XML based
ISO20022
Solution Overview

6. Easy Steps to Get Started
Onboarding
6

7. 7
Reporting
Premier 9 Reporting Platform

8. 8
Reporting Flow
Reporting

9. 9
Exception / Data Quality
Management
EM-1
Step 1: Error Identification
by P9 Solution.
Step 2: Customer Service
Team contact customer to
resolve.
Exception Management Processes
EM-2
Step 1: Error Identification by P9
Solution.
Step 2: Customer Service Team
contact customer to resolve.
Step 3: End-of-Day Report sent
to customer.
EM-3
Step 1: Error Identification by
End-Point.
Step 2: Customer Service Team
contact customer to resolve.
Step 3: Email notification with
feedback sent to customer.
Error Resolution

10. 10
Reconciliation Service Point Nine
Client
Feedback to Client
Reconciliation
3
Reporting/Counterparty Data Flow
1
Reconciliation
2
Feedback to Counterparties
4
2
1
3
4
1
Counterparty 1
Counterparty 2
Counterparty N
Dashboard

11. 11
P9 Recon
RESULTS
IN TWO FORMATS EMAIL SUMMARY WEB PORTAL
Reconciliation
INPUT PAIRING MATCHING VALIDATION
SOURCES PROCESS PROCESS PROCESS

12. 12
Client Portal

13. www.p9dt.com 13
Summary Email Reports
Clients can select whether to access the portal or to simply wait for the End-of-Day email
summary sent directly to their inbox with a detailed, comprehensive report of the day.
Email Reports Frequency EMIR MIFIR SFTR Notificatio
ns
Daily Summary Daily Y Y Y Y
End of Day Dailly Y Y Y Y
Onboarding Once we have a
file
Y Y Y Y

14. 14
Validations
EMIR MIFIR SFTR ASIC
• T+1 Warning (Deadline notification)
• Dates Check (i.e: Execution cannot be in the future,
Maturity/Termination cannot be prior to Execution)
• Quantity / Notional Check (Warning Exceed Quantity or
Notional threshold)
• P9 Validations (Check digit, Pattern)
• LEI
• Expiration (Notification in advance)
• Check LEI issue date and compare with execution date
(ESMA: No LEI, No Trade)
• Reference data and ISIN data reconciliation
• LEI of the issuer and Jurisdiction of the issuer
• Maturity of security, Security quality and type
• Full CFI Validation (Pattern, Possible values and position, use
CFI to check other values (Delivery, Option Type, Style, Asset
Class / Type )
Reconciliation & Validation Engine

15. Validations
EMIR MIFIR SFTR ASIC
• MIFIR Annex II (Individuals)
• Construct CONCAT
• Priority checks / Pattern checks (Passport, Id, Tax Id)
• Individuals year warning (> 18 or < 100 years)
• Individuals and Companies name - check (“test”, “testing”,
“name”, “noname” etc.)
• Statistical analysis
• Products Rules:
● Quantity currency must be blank for Quantity type = Unit
● Quantity for bonds should be nominal or monetary value
● Quantity for spreadbet should be monetary value
● Price for options should be monetary value.
● Price for spread bets should be monetary value.
15
Reconciliation & Validation Engine

16. Validations
ESMA Data Quality Report April 2022 Point Nine Solution
- 13 out of 40 jurisdictions have a late
reporting rate above 20% and a few are
even above 40%
- P9 requests clients’ data to be sent the
earliest possible within the day. In this way,
P9 will have sufficient time to communicate
with the clients and/or their counterparties,
if necessary, fix any errors and proceed with
timely submission
- 20% of open derivatives subject to daily
valuation have not received updates for
several days, months and even years
- Valuation report is being submitted along
with the positions report on a daily basis. In
case of missing valuation , clients will
receive the missing valuation notification
- Trade pairing is only at 60% at the end of
2021
- During the onboarding stage we will
implement a comprehensive UTI solution.
Transactions can be reconciled and
pre-matched prior to the submission
between our client and their counterparties.
In case of unpaired trades, P9 will
investigate and identify the discrepancies in
order to re-submit the unpaired records
16
Reconciliation & Validation Engine
EMIR

17. …Validations
ESMA Data Quality Report April 2022 Point Nine Solution
- Abnormal values for multiple fields
- P9 has set thresholds to capture any
abnormal values such as quantity above *
or zero price etc.
- Approximately 30 million trades per month
are not reported
- Reconciling clients data with P9 system will
eliminate the possibility of missed records
- Difference in number of records reported by
the two sides
- Since all the records can be pre-matched
between two parties, the number of records
is reconciled as well. The feedback from the
TRs enters P9 engine and in case of
un-paired records, both clients and P9 team
will be notified. The discrepancies will be
investigated and rectified.
17
Reconciliation & Validation Engine
EMIR

18. Validations
18
- Errors in price-related fields
- Validations that prevent errors in price
related fields are in place
- Unique national identifiers (inaccurate
reporting)
- Checks regarding the pattern of every
unique identifier as well as the priority
specified in Annex II of the Commission
Delegated Regulation (EU) 2017/590
- Misreporting of Buyer and seller decision
makers
- The reporting specifications regarding buyer
and seller decision makers are
communicated during the onboarding
process in order to avoid misreporting of
these fields
- Incorrect population of Executing entity
identification code
- Executing entity identification code is
pre-defined and validated before the
submission
- Misuse of the aggregate client account
- This will be discussed during the onboarding
process and validations will get in place. The
aggregate client account will not be used for
any other purpose than set out in the
applicable guidelines. The data are being
reviewed before the go live so any possible
issues can be identified
Reconciliation & Validation Engine
MIFIR

19. …Validations
19
- Misreporting of indicator fields (61, 62, 63
and 64)
- Fields 61-64 are checked based on the
pre-agreed rules with the clients
- Inaccurate details for trading date time - P9 engine can accept any time format in
any timezone. This will be validated (time
out of trading hours based on MIC code,
time cannot be in the future, late reporting,
prior to MiFIR go live date etc.) and
converted in UTC before submission
- Misreporting buyer and seller identification
codes
- Multiple validations for buyer and seller
identification codes are in place (follow the
correct pattern, meet the Annex II priority
etc.)
- Instrument reference data - high volume of
transaction reports being rejected where the
relevant instrument is not valid
- The eligibility of each instrument is being
checked from P9 eligibility tool prior to the
submission of the relevant records
- Errors and omissions - firms have identified
errors or omissions in their transaction
reports but failed to cancel, correct and
resubmit corrected reports to the NCA
- Once client fills in the relevant form and
inform NCA of errors or omissions that have
been identified, P9 will correct and resubmit
the data
Reconciliation & Validation Engine
MIFIR

20. Validations
20
ESMA Data Quality Report April 2022 Point Nine Solution
- In some jurisdiction above 20% of open
SFTs have been reported with the event
date being later than the reporting
timestamp.
- Validations that do not allow this scenario to
occur. Clients will get notified in case of
event date dated in the future without the
relevant records reaching the destination
- >2% of records rejected on average
- Since all records are validated prior to the
submission, the percentage successful
submissions is 99.95%
- 60% pairing rate by the end of 2021
- Following P9 UTI management process, all
the numbers are pre-matched , hence the
pairing rate is close to 100%
- Loan matching rate at around 50% by the
end of 2021
- Any discrepancies can be identified during
the reconciliation and pre-matching process.
Loan and collateral components matching
rate can be as high as 100% as long as the
data is pre-agreed between the
counterparties
- Collateral components matching rate at
around 20% by the end of 2021
Reconciliation & Validation Engine
SFTR

21. Regulatory Reporting fines
21
1. ESMA PUBLISHED SANCTIONS IMPOSED BY NCAS OF 12.2 MILLION FOR MIFID II BREACHES
IN 2021 8 July 2022
2. The Commodity Futures Trading Commisssion ordered, JPMorgan Chase Bank N.A., J.P.
Morgan Securities LLC and J.P. Morrgan Securities, to pay $850,000 for failing to report
approximately 2.1 million short- dated foreign exchange (FX) swap transactions from September 2015 to
February 2020, 05 July 2022
3. The Commodity Futures Trading Commisssion ordered, BNP Paribas, to pay $6 million for
violations relating to swap reporting and daily mark disclosures, 05 July 2022
4. Goldman Sachs International (GSI) has been fined £34,344,700 by the Financial Conduct
Authority (FCA) for failing to provide accurate and timely reporting relating to 220.2
million transaction reports between November 2007 and March 2017.
5. UBS breached the Authority’s rules, as found within its Supervision manual (“SUP”), requiring
firms to submit complete and accurate transaction reports.
6. Merrill Lynch International (MLI) has been fined £34,524,000 by the Financial Conduct
Authority (FCA) for failing to report 68.5 million exchange traded derivative transactions
between 12 February 2014 and 6 February 2016.