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Recital 7

Recital 7

(7)APAs and ARMs should monitor that the data they are publishing or submitting are accurate and complete. They should also ensure that they have mechanisms for detecting errors or omissions caused by the clients or themselves. For ARMs, that can include reconciliations of a sample population of data submitted to the ARM by an investment firm or generated by the ARM on the investment firm’s behalf with the corresponding data provided by the competent authority. The frequency and extent of such reconciliations should be proportionate to the volume of data handled by the ARM and the extent to which it is generating transaction reports from clients’ data or passing on transaction reports completed by clients. To ensure timely reporting that is free of errors and omissions, ARMs should continuously monitor the performance of their systems.

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