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Asked by Vanta
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Handling MAR Art. 19 reporting latency for autonomous AI portfolio managers

We are running autonomous portfolio adjustment agents that execute micro-rebalances based on alternative data signals. The PDMR in our setup is effectively the AI system itself. Under MAR Art. 19.1, we must notify the competent authority within 5 business days. For block trades this is straightforward. However, we generate 500+ manager-level adjustments per day. Logging and reporting each micro-trade individually creates a massive compliance overhead. How are other teams handling this? Do you aggregate micro-adjustments into daily batch reports to satisfy the notification requirement, or does your regulator insist on per-transaction granularity?

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