1The FCA will treat a firm as acting in accordance with SUP 17.2.1 R in circumstances where the firm enters into a transaction with another person in the course of providing a service of portfolio management on behalf of one or more clients, provided it:
has reasonable grounds to be satisfied that the other person will, in respect of the transaction, make a transaction report to the FCA (or to another competent authority) which, as to content, will include all such information as would have been contained in a transaction report by the firm (other than as to the identity of the firm's client).
1The FCA will expect a firm which seeks to rely upon the waiver in SUP 17.2.3 R to take reasonable steps to verify that transaction reports will be made in accordance with the standards laid down in this chapter and in particular should ascertain and remain satisfied that:
the terms of the agreement between itself and the relevant trade matching or reporting system, regulated market or MTF, make appropriate provision obliging the provider of the transaction reporting service to make transaction reports on its behalf;
the arrangements provide for confirmation in each case that a transaction report has been made on its behalf.
21The operator of , an approved reporting mechanism2, or the operator of an MTF or a market operator through whose systems a reportable transaction is to be completed and which has, pursuant to SUP 17.2.3 R, agreed to make transaction reports2 to the FCA on behalf of a firm, must:2
The obligations of the operator under this rule do not affect the liability of the reporting firm for ensuring the accuracy of the information contained in the transaction report that it submits to the operator.22
Reporting obligations under this chapter do not affect any obligation to report transactions under the rules of any market, trading system, matching or reporting system or exchange, whether or not that market, system or exchange is a regulated market.