The REGIS-TR RoundUp
The REGIS-TR RoundUp is a hub for regulatory reporting news and views from your leading Trade Repository team and industry guests from across the globe.
The REGIS-TR RoundUp
S11:E05 2026 Consulting Special: RegTech, Operations and RegOps with Cappitech
Start 2026 with practical, hands-on guidance for improving operations and regulatory reporting.
Join our virtual studio with special guests Igor Kaplun and Jonathan Tsang from Cappitech as we focus on optimising operational and reporting data flows from front office through to post-trade.
We're discussing RegTech and RegOps strategy, data quality, reconciliations, and how firms can use this regulatory “quiet period” — with no major rewrites or refits expected in the next six months — to fix internal processes, controls, and operating models.
Our guests bring deep, practical experience working with market participants across asset classes and will share what works, what doesn’t, and where firms should invest time and effort now to reduce risk and costs later.
Plus, as always, analysis and perspective from our Trade Repository team.
And welcome back to the Register Roundup for 2026. Yes, Happy New Year. We are back live and direct with a show that is going to be setting your agenda for 2026. Yes, we're enjoying a little bit of a lull in the endless waves of rewrites and refits and new regulatory regimes kicking in. And what better time to get some experts on who can give us some good hands-on practical advice about how we can improve our operations, improve our reporting processes, and generally get ready for when the next waves start to hit. Of course. Before we introduce our experts, we do also have our virtual studio crew here today as well to give us the TR angle on all of this. And that is in no particular order, starting with the man who uh used to put the canary in the wharf. Then he was Devonshire and never square. And now he commutes relentlessly between Luxembourg and London, his friends at the FCA. It is, of course, Mr. John Kernan, the head of uh Registry R UK. John, welcome back.
SPEAKER_06:Thank you, Angie. Great to be back. Happy New Year, everybody.
SPEAKER_01:Great. Did you have a good Christmas?
SPEAKER_06:Uh I had a very nice Christmas, quite quiet, but uh that was great. And then I headed to Dorset to see the family uh for New Year. So lovely. Yeah.
SPEAKER_01:Great. That sounds good. That sounds good. What are your new year's resolutions, John? Anything special we should know about? Any TR resolutions?
SPEAKER_06:No, no resolutions at all. I'm going with the flow. That's my resolution.
SPEAKER_01:And of course, someone who always goes with the flow, of course, is uh my most regular co-host, the voice of reason himself, the head of business development and registering our essay. Uh it is, of course, Mr. Nicholas Bruce. Nick, welcome back.
SPEAKER_05:Good to be back, Andrew. And um, yeah, happy new year, everyone.
SPEAKER_01:Uh, did you have a good Christmas, Nick?
SPEAKER_05:Yeah, um, a bit like John, quite relaxed, very chill, just had the family around and um it was enjoyable.
SPEAKER_01:Excellent, that's good. Do you have any New Year's resolutions or are you like John, just going with that flow?
SPEAKER_05:No, well, I'm taking a different view this year in the I never keep my resolutions. So I thought, why not do it in reverse? So this year my resolution is to drink more and do less. Um, in the hope that that will psych me the other way. So we'll see how it goes.
SPEAKER_01:That's actually that's a great idea. Drink more, do less, put on weight. Then should be on that list as well.
SPEAKER_05:Well, absolutely. Grow the moobs, go all in. Why not?
SPEAKER_01:And and reduce the exercise to the bare minimum. I think that's an excellent list to work with. Uh, I like it. Reverse psychology there. That's why we call him the voice of reason, Mr. Nicholas Bruce. Uh, and of course, joining us, uh, well, special guest, one, of course, uh, I'm going to introduce now, someone you've heard on the show a few times over the years, an expert on securities lending and repo and all things to do with data quality and reporting in the securities world. It's Jonathan Sang. Jonathan, who has an excellent and and you know, predictably long uh job title. He's the head of business development uh for uh Amir at uh Capitec. Jonathan, of course, has been in the business a long time. Uh he joined Capitec in 2018. Um he started out interestingly, he's overlapped with Jon and Nick uh on his uh excellence CV because he worked at HSBC like Nick. He worked at State Street, uh like Jonathan, and uh after that moved into um Capitec and IHS Markets first, of course, then Capitec and now SMP. Jonathan, welcome to the show.
SPEAKER_02:Thank you. Um thanks for having me back. Um glad to be back and to uh talk about all things regulatory reporting. And did you have a good Christmas?
SPEAKER_03:Yes, I did. Um went to Hong Kong for two weeks, so that was nice with the family.
SPEAKER_01:That sounds lovely. And do you have uh a reverse psychology New Year's resolution for us?
SPEAKER_03:Well, I don't normally do resolutions, so I might as well keep with tradition.
SPEAKER_01:That's good. No resolutions. That's that's uh there's a theme emerging here in the financial services world uh for the listeners there, which is you know, focus on the regulations. If Esma doesn't uh mandate it, frankly, don't do it. Uh and of course, our other special guest this week, uh who's joining us ahead of Capotech Consulting uh is uh Igor Kaplan. Igor, you will know, I am sure, from if you've done anything in the world of regulatory reporting, uh you will probably know him. He, of course, started uh out uh in uh 2009 at the CME group, uh working in information products and worked his way through there uh through to being the uh head of uh commercial development for the US and Canadian TR side. So a real TR expert. He then became the head of regulatory reporting and business development at IHS Market in 2022 and is now head of uh Capitec Consulting. Uh and Eagle and Jonathan will be giving us lots and lots of advice. Sorry, not trying to set you up here, guys. Lots and lots of advice on how you should be approaching 2026. Eagle, welcome to the show.
SPEAKER_00:Thank you very much. Uh a pleasure to be here.
SPEAKER_01:And Eagle, I just want to check. Did you have a good Christmas? And are you going to buck the trend of the New Year's resolution advice?
SPEAKER_00:I I did have a good Christmas, thank you. Uh was uh was here with with family here in Chicago. Um and um I'll actually take a a page out of out of both Jonathan and and Nick's book here. So no resolutions and maybe a little bit of that reverse psychology of uh um of do less in in 2026. So that's uh that's my focus.
SPEAKER_01:Okay, somehow I don't think you're gonna be doing less in 2026. I'm just I'm guessing now that that never seems to come about for our guess. But talking of 2026, let's get into the the the proper show here because um looking ahead, this period now, it feels like a bit of a an inflection point for the regulatory reporting industry. Um, we don't have any major rewrites on the cards immediately. Um uh I I want to ask you, how have you seen firms change their priorities and their focus for the coming year?
SPEAKER_00:Yeah, I think that's that's a you know it's a good way to kind of set the scene for for you know for 26. Um, you know, we've gone through a period over the last three to four years of constant regulatory change uh across Europe, APAC, North America, and um 26 and even going kind of beyond that 27, you know, potentially is really the first time that there's a uh a significant break in that regulatory change agenda. And you know, what we've seen, even even going back to the second half of 25 leading into 26, is firms are really using this opportunity to to focus on more strategic initiatives um around their their core business, but really also around um you know their reporting infrastructure. Um, you know, I think the challenge the industry has seen over the last couple of years is when you have a regulatory deadline, um, that's your that's your number one focus. There's really there's really very little time or energy or budget to do anything else beyond just hitting that next, you know, next compliance state. And so 26 presents an opportunity for a lot of firms to really take a step back and think about things a little bit more strategically. You know, do I have the right infrastructure in place? Do I have the right controls? Do I have the right personnel? Am I thinking about my, you know, my counterparty relationships in the right way, about you know, where I delegate, where I don't delegate. And so this sort of pause in the regulatory agenda is really a positive for the industry, I think, beyond just the um uh you know, the fact that I think everyone is tired and and and sort of exhausted from the constant change, I think it's just it's a it's a it's a good opportunity to really you know look at things without without that um you know hard deadline kind of staring at you. And so um what we have seen in the market, and this is really a kind of a global um view and both across sell side and buy side. So you see really the full kind of gamut of market participants thinking about it in a very similar fashion of using 26 to to kind of you know relook at their um at their existing process.
SPEAKER_01:And Jonathan, I mean I I want to ask you about this as well. The focus now, uh or at least a lot of the buzz, is around okay, how do we simplify uh and reduce the the burden on market participants when it comes to regulatory reporting? Uh is that something that's coming up in the conversations you're having uh uh from the sort of business development perspective there at Capitech?
SPEAKER_04:Yeah, I mean for sure. I mean it wasn't it almost didn't end up like this if you think about it.
SPEAKER_03:If you wind back probably, I don't know, six or so months ago, you know, NESMA did come out with the call for evidence that kind of put MiFID, the next stage of MiFID, on hold. Um if you're tracking things around the US um that um around SEC, for example, and as in particular 10C-1A, um that could have had a very different 2026, but that regulation itself has been pushed out to 2028. So, you know, as Eagle was saying, with these regulation rewrites and new regulations sort of moving out um, you know, of any significant size and change, um, the focus has moved towards what um clients should be doing uh around their data accuracy, their completeness. So is this a case of clients um looking at their um how they source their data, put their data together, um, to the point of um also controlling what's been reported. Yeah, they're all definitely key themes that we hear about. Um we we we hear about clients wanting more control over their data accuracy, their completeness, etc. But also um, you know, that's almost like a remediation exercise. And anyone who's involved in trade reporting um, you know, won't really enjoy a remediation exercise because of all the pain that it brings. So then, you know, you should open up the door to clients to investigate root cause and look at how their data architecture is has been put together and whether it can be improved. So hence simplifying it.
SPEAKER_06:Yeah, I think also, you know, having this window where things are relatively speaking quiet, uh, you know, with my with my email hat on, uh, as Jonathan was saying there, it it presents an opportunity to to get your data quality in shape. Um Eagle mentions you know, reviewing your counterparty relationships as well. And I'm thinking all of this with the uh refit stage two reconciliations uh coming into force.
SPEAKER_01:And on that front, Nick, uh, you know, when we talk about this being a quiet period, it's probably quite good if if you can just frame that for quiet is a relative term, isn't it? I mean, there are quiet periods and then there are quiet periods. It's not like everyone's sitting around, you know, uh enjoying uh a Mars bar and a lengthy lunch uh lunch break, is it? I mean there's there's still a lot going on.
SPEAKER_05:No, there's there's a hell of a lot going on, I guess, is the simple answer to that. As always, I think maybe the focus has changed slightly in terms of the immediate kind of agenda. And I think we've been saying for a long, long time, especially when we had this kind of tsunami of rewrites that um happened globally over the kind of the last sort of 18 months, two years, was that we just needed a period where uh things would just stabilize so that people could look at the core, could look at their systems, their platforms, data quality. Because it'd been very much about kind of meeting the next requirement and then moving on to the next challenge. So, as Igor said, it was these deadlines. But it seems strange that we're talking about uh relative quad when actually what we have is we have a shadow of huge change uh hanging over the industry as well at the same time. We've talked about, you know, we mentioned briefly Esma's call for evidence. You've also got the FCA who again are doing their own consultation where they're looking at improving transaction reporting. So uh there is a lot of change going on, and I think at the moment, you know, we just don't know what that's going to be and what that means. So I think for firms it's a case of focus on the immediate priorities, what you can, and use this opportunity. But we know that in this background, there's still a lot of work that we're all having to do to give input into these reviews. Um, and then on the back of that, we then need to see what the output is, what this really is going to mean for the industry.
SPEAKER_06:Yeah, I mean, I guess Nick, I I think you're hitting the nail on the head there as well. What I was going to say was with the with these consultations, they're they're lengthy and they're complex and they cover uh so many almost almost every area of the business. And so even replying to a consultation paper like that represents a significant body of work across, you know, operations, IT, strategy, compliance, etc. etc.
SPEAKER_05:Yeah, completely. I wish we had Laura on the call. We're we're missing out because Laura, to be fair, that's probably the hour gone with Laura started telling you all the things that we're actually looking at in terms of papers from the regulators. So as I said, you know, it is a relative, you know, quart is a relative word. And I think there is that there is a lot going on in the background which is going to sort of shape that agenda for the next sort of five to even seven years.
SPEAKER_01:Well, this is obviously something from a consulting point of view that must come across your desk a lot. Uh you know, uh, Igor, you know, regulators are increasingly using calls for evidence, aren't they? Um, to try and understand more about how reporting works and also obviously what doesn't work. Uh, I mean, how are you advising firms to uh approach uh calls for evidence? Is it an opportunity to reduce duplication and cost and sort of just hand over uh some useful tips, or is it more about lobbying the regulators like ESMA for change? Are you advising firms uh to use this as an opportunity to review their own processes and then you know feedback to ESMA and saying, actually, it would work better and you would achieve more of your goals if you did it like this?
SPEAKER_00:Yeah, absolutely. I mean, in like in the context of how we're engaging with with firms, it's really about things that we can control now and things that you know firms can control now. You know, I think I think the point was made earlier that we do have this big unknown that's kind of hanging over us with the call for evidence and and sort of other proposed refits. Until until there's there's any certainty into what that actually means and timelines, there's really very little that you can do to sort of you know prepare for that beyond following the consultations, following the discussions in the in the working groups with the trade associations, with the trade repositories. And certainly there's a lobbying effort that I think the industry is doing, either, you know, clients doing that directly themselves with the regulators or through trade associations. Um, you know, kind of what, you know, you know, what we can do from a practical perspective and what we're focusing on today is things like a health check or health assessments, right? You know, coming in and doing an independent review of a client's reporting infrastructure, um, reviewing their data, looking for anomalies, looking for uh inconsistencies in how they've been reporting, um, addressing things like their governance model, addressing um, you know, what controls do they have in place. Those are those are uh initiatives that firms are really focusing on now, uh, you know, to some degree in preparation for any future changes, but really it's more about I think, you know, what's the right thing to do for the business? Um ultimately, you know, the the wave of of rec change has certainly slowed down, but it in the backdrop is is the fact that you have regulators around the world that are very, very focused on data quality. And you know, and just in the past you know few months, we've seen that the regulators in Hong Kong and Singapore and Australia, certainly the NCAs in Europe, you know, they continue to really um analyze the data being reported to them in a very, very significant way. And and um, you know, practically, you know, the regulators are reaching out to firms directly, asking questions, asking for explanations on why they reported a particular trade or a series of trades in a certain way. And so there's very real feedback that that the industry is now getting from regulators on data quality issues, and that's really forcing everyone to really think about how and why they're you know they're doing something. Um, and that's the opportunity I think that kind of presents itself this year. And this is really where our teams have been very um you know, very much engaged um to you know to assist clients with that regard because it's a pretty in-depth exercise to really go back to your books and records, to go back to how you're capturing traits in your um in your front office system and your trade capture system to understand how that flows through into your reporting system. Um and really what you would want to do if you are doing that type of assessment is you want to have an independent view, right? The people that are involved in running that process for you as a BAU uh function, um, you know, you probably want to have that separate um in terms of some sort of assessment or investigation to that. Um and so those are the types of things that we're seeing um firms focus on. Um, and I think the other kind of um more macro piece that you know that's out there is um there's still a lot of change happening in the industry from a business perspective. There is uh you know, there's a lot of consolidation as an example in the US, uh you know, around regional bank sort of consolidation, there's a lot of MA activity. You have new entrants in the market in Europe, in the US, in crypto and prediction markets. You constantly constantly have this change that's happening in in a business environment, right? Launching new products, entering new jurisdictions. Um, all of that's still in the backdrop, and all of that change still has a regulatory component, and that's always going to be there regardless of what the regulators are are thinking about from a you know specific rewrite or refit.
SPEAKER_01:And is there a business value that comes from those kinds of exercises? I mean, we've we've often talked on the show about the fact that that although it feels like it's just a a cost to get your in-house data in order and improve the quality, actually there are secondary gains that you get from this, which is sort of it's it's good medicine, right? For the the business to actually take some time to reflect and improve their processes.
SPEAKER_03:Yeah, so I think you know, if you if you started a business from the very start, um and you had you know, you just wanted to be commercial enough, you'd you'd probably maybe shave a few corners here and there to get to your end game, and whilst not building all the right, you know, processes in place. And now with all these remediation. Or with all these checks needed for your data governance and that kind of stuff, you now need to reevaluate how things have been put together. And you want to put things more robustly. So the upshot of all this data accuracy and completeness is that you will know where you're getting the data from, how accurate it is, which then can improve not just the reg reporting side of things, but perhaps anything that stops it from settling in the market, which has a real market impact. So that's an I think that's another interesting piece that can come out of this. Um but I think certainly getting your data in order will help. Um you'll you'll find that you'll get you'll fix a lot more of the upstream issues. Um so by the time that it gets into the reporting phase, um the data is already complete.
SPEAKER_01:Igor, I want to come back to you on this one. Uh, but for you and Jonathan, do you get pushback sometimes from clients who say, well, we've always done it this way? Uh why do we need to change it? Is that something that's is that too controversial a question? Uh, because I think we've all encountered in our careers at some point the not invented here syndrome. Um, but of course, this is change that's being imposed from the outside. Is there resistance to do firms naturally want to improve uh their processes to fit with Esma or do they feel like sort of pushing back and saying, hold on a second, why do we have to make these changes?
SPEAKER_00:Yeah, it's an interesting question. I mean, um, there are still many conversations that I have with clients where they are still sort of moaning about, you know, you know, why do I have to do this? I mean, that still does come up every now and again. I I think it's probably more the exception than the rule these days. I think, you know, we're if if I go back to the the start of of sort of reporting in you know 2011, 2012, I mean, we're over a decade into this now. And so, you know, that ship has sailed. It's sort of, you know, it is what it is. And, you know, we have to sort of do our best to, you know, to, you know, to you know, to meet the obligations that are, you know, that are kind of put out by the regulators. Um, I think what's happening kind of, you know, kind of back to the to the earlier question a little bit is that um those insights are are interesting in that um where firms can connect their front office sort of trading uh activity to what's happening on the post trade, um, there's a lot of really good things that they get out of that. And you know, kind of what I mean by that is um, you know, in many organizations historically, those two things were completely separate. So I handle my trading activity, trades booked, it's confirmed, it's settled, and now it goes to another team. And, you know, whatever they do with it to you know to comply with the reporting obligations, that's none of my business. That concept doesn't exist anymore in many of the firms that we speak to, front office and even up to the executive management teams at many large organizations that are highly regulated, they are very, very focused on what's happening in the reporting space. And the reason for that is reporting for the regulators, it becomes a very easy thing to, you know, to look at, you know, to identify issues or gaps that potentially are more upstream than just reporting. Um, as an example, if you look at some of the enforcement action that's that's taken place in the US by the CFTC, whenever they publish any sort of fine, they talk about, yes, you know, somebody you know didn't report um this particular product or they didn't report some valuation for the last three years. Um, but what they also talk about is the lack of controls and the lack of governance. And they always, every single one of those enforcement actions talks about a gap that's much more upstream in the process to reporting that's identified as part of this audit or part of this investigation. And that's really what I think is opening the eyes of a lot of firms to really think about how do you put the right controls in place much, you know, much further upstream than just at the tail end of the entire process and just getting a trade out the door into a trade repository.
SPEAKER_03:Effectively, if you join it up a little bit more um across the board, then it will be then everyone's got a stake in it. I mean, if you look at uh it was just happening the other day, I was talking to a client and uh um their front office was involved because the front office wanted to trade something, but it hadn't been all clumbed in um in the back end to defeat the reporting um for for SFTR in that situation. Um so you can often I often speak to clients where reporting is you know a massive priority to get up and running um because it's prohibiting their desks from from trading that product. So you if you if you ensure that all the pipes are plumbed in from uh front to back, then you've got a good um foundation. And so, you know, as in when you start trading new products or or plumbing new systems, etc., reporting is always a consideration. Um and and also you know, static data as well, ensuring that that is complete, counterparty static information, that that kind of stuff, you know, ensuring that that's all in in-house enables you to report correctly.
SPEAKER_01:Well, I want to come to some sort of you know, uh discussion around actually what firms should be doing uh and and start and how to start that journey. But before we get to that, I wanted to bring up reconciliation too and what that sort of signals, because it's been framed by some people as a technical cleanup, and it feels like the good time to sort of look at that and say, okay, from your perspective, is this one of those moments? Is getting ready for reconciliation too, is that really about revealing sort of deeper level sort of structural problems uh because you don't have your Reg ops in place, you can't just implement that system, you're gonna need to make some changes uh to get ready for Rec 2, um, which is also a fantastic uh horror film, if uh Spanish uh film, if you if you've uh seen that anyone, I'm just gonna drop that one out there if anyone's a fan. It's actually much better than Rec 1, I think. That's that's my view. Um controversial. I know Igor's laughing, he he's seen it. Great. Uh finally, someone who gets my references. Um so so sorry. Uh I'm sorry, I digress. Getting back to it, getting ready for reconciliation too. This is that great moment for you to start your RegOps journey. Do you do you think that's uh a good suggestion, Igor?
SPEAKER_00:Yeah, I mean, I I think if you look at you know uh Rec2 and and it it it's it's really part of a broader kind of um focus or concentration, which is which is around data quality. It's um does the data of the year report actually make sense? Um right. That's that's ultimately the question that I think we're all trying to answer, and the firms are trying to answer, and the regulators are really focusing on. And so reconciliation in its current form and then you know, kind of with the upcoming changes in in Europe, um, really try to address um a data quality mandate that the regulators are putting out there. You know, Jonathan touched on this a little bit earlier is that um data quality is really seen in the context of um of completeness, accuracy, and timeliness, right? Those are the three sort of you know KPIs, if you will, around um data quality. Reconciliation generally focuses on the completeness aspect of it, right? Did you report everything that you should have reported? And does the data in your books and records match to what's at the trade repository, which is ultimately what the regulator sees? Reconciliation becomes a uh a very effective way to obviously identify issues. I think the challenge with Rec, and now with this expansion to additional data fields is there could be a lot of noise. And that's the problem, right? When you're talking about reconciling, you know 20 fields versus 150 fields or 200 fields, the amount of stuff that you may get out of that reconciliation could be huge. And now the question is, well, you've identified that there's some gap between your data and what's at the TR. What do you do with it? And I think that's the challenge that a lot of um, you know, a lot of firms face from an operational perspective. And, you know, it's it's sort of do you just focus on resolving breaks or do you actually do root cause analysis and go back to why is this breaking? Why do we continue to see the same issues or the same counterparty or the same product or the same type of transaction? And so reconciliation is a is a huge opportunity for firms to um to you know, it forces them to investigate their data. And I think what what's important to mention outside of of you know what you know what Esma is requiring, reconciliation is pretty much mandated in every jurisdiction now. The regulators are sort of forcing the handle of the industry to say you have to verify your data. It's no longer a nice to have, it's really a must-have at this point.
SPEAKER_06:Yeah, I mean, I'd I I'd agree with what Igor just said, and you know, I am a great advocate for uh double-sided reporting. Um I just think it's interesting, you know, at stage where that where the um existence of double-sided reporting is be is is being questioned in the call for evidence, and at the same time, we're about to implement a whole um whole series of additional uh data points to be reconciled. And it I think it just really raises the question is is the reconciliation, or certainly post uh recon too, is the reconciliation disproportionate because it just strikes me that, for example, you you wouldn't reconcile anywhere near that number of fields for for actual market settlement where where the risk is much more significant. And I think you know it's because of that potentially that you have so much um industry pushback and lobbying um for the removal of double-sided reporting. I I feel potentially that wouldn't be the case if the reconciliation was was more proportionate.
SPEAKER_05:Yeah, it's it's a strange one, isn't it? Because we've reached a point where, you know, certainly when you look at what's happened with Amir and Amir Refit, the focus has actually been well, the data quality isn't where it needs to be. And the way to resolve that is to increase the number of fields and certainly the number of fields that need to be reconciled. But where you see a lot of the pushback and that move to single-sided, actually, some of the kind of the conferences we've been to, some of the responses that we've seen as well around the call for evidence isn't necessarily pushing because it uh the industry wants single-sided, it's because of the burden for reconciliation, so they believe is too much. And really it should be focusing on what are the key fields that need to be reconciled. So if you're looking at systemic risk, what do you actually need to reconcile to ensure that you've got the date, the right data and the correct data, but are the points that you're really analysing? So I think that's the question is is it a question of you know, is the reconciliation where it needs to be, or should it actually is it something that just really needs to be refined? Because ultimately firms already built the reconciliation engine, so it's already there and it's up and running. But I think that's going to be the big kind of questions come, you know, or the big question that we've got hanging over us from the call for evidence. I can see Jonathan's itching to get in there.
SPEAKER_03:Well, it's funny you mentioned that. I mean, maybe we f we go full circle, and and John, if we go back to the beginning of uh the TRs, we once sat around a table and decided what should be reconciled, um, especially in terms of I think it was priority one and priority two. And priority one would deemed you know fields that actually affected matching and settlement. And then priority two were the sort of maybe things that Esmer wanted to see reconciled as a nice to have, but we knew that there was a chance that they would not be paired or it would not be matched, um, but still give some sort of insight so so as to not completely strip it away. Um and I think the amount of feels I'm I'm sure our listeners would love to hear was probably around the 30s, um, back in those days. So, you know, if if the caller for evidence, if Esma does anything with the caller for evidence in terms of maybe listening um to industry, um, and maybe if it goes in that direction, that could um be quite that could be a good middle ground uh in terms of keeping the dual-sided reporting nature of the regulation, um, but also having you know something that makes sense rather than a huge huge amount of noise.
SPEAKER_06:I don't know if it's helpful to speculate, but um, you know, perhaps the direction that is the direction we we'll end up at because obviously ESMA themselves have been a defender of double-sided reporting for uh, you know, for obvious reasons. Um, and it's our understanding also from the conversations we've had with national competent authorities as well, that that they would be extremely reluctant.
SPEAKER_01:Okay, good. Now, sadly, we have to start drawing these threads together. And uh I think the upshot of where we've got to is it's time for some good advice. If you're gonna give a steer to firms who know they're not gonna be, you know, spending the vast sums to replace core systems uh in the near term, how should firms be prioritizing their investment in reporting infrastructure to address the amount of manual labor that's going in to uh reconciliation activities, to improve their data quality, to actually get the systems in place? Is this about targeted automation and those kind of solutions? Are we talking about finding vendors that can support the sort of business as usual activities and you know, supply managed services on that? What what sort of advice should uh firms be taking about how to improve their approach to data quality and reporting to reduce that burden on themselves? Eagle.
SPEAKER_00:Sure, yeah. I mean, I I I think a a good place to start is always to um is to identify where you are today, right? What is your current state? And um, you know, you can do that analysis yourself. You can, you know, you can bring in an outside uh sort of consultancy or there's you know, there's all sorts of tooling in the market. Um, you know, there's there's opportunities to you know to really do an independent assessment on where are you today and and sort of where are the gaps. Um as the old kind of adage goes, you know, you don't know what you don't know. Um and when you're knee deep in sort of BAU, it's really hard to really take a step back and see, am I doing it the right way? You know, where are the issues? It's you, you know, you're really focused on just getting the trade in and you know, kind of running your BAU process. And so I think as a starting point is identify where your where your you know you know challenges are, where the issues are. And then from there you can figure out, you know, what sort of remediation, what sort of you know, kind of initiative should you undertake to actually get to a better state. And thinking about that better state is you have to really think about what is your target, what is the operating model, what is the end state that you want to get to. Um, there has to be some, you know, some goalposts that that you need to identify um on what you know what you're um you know, what you're targeting. So as an example, there are some firms that we've spoken in the market that say anything less than 100% accurate every single day is not good enough. You know, you know, they've set the highest bar for themselves, and that is a very difficult threshold, you know, to meet, you know, regardless of size or sort of um complexity of the firm. Um, and uh ultimately I think once you can figure out you know where the challenges are, what your target is, it's really figuring out that remediation on how to get there. It could be a technology solution, it could be an operational solution of adding staff, uh additional training, it could be outsourcing, it could be um bringing in some tooling that allows you to really focus on the