ToTV or not ToTV – That is the question.

In this opinion piece, we look at how it’s impossible for firms, even an ARM or APA, to determine with complete accuracy if an instrument is in scope for reporting at the time those reports are made. Having illustrated the problem, we go on to explore how a firm can meet its regulatory obligation to take reasonable steps to verify the completeness, accuracy and timeliness of the reports – even where submitted by a third party – providing visibility to management and allowing corrective action to be taken.