Robert Mitchell
26 May 2017 5:11pm
Will RegulatoryTransactionType (2347) be expanded to include “the regulatory mandate or rule that the transaction complies with” for MiFID2?
Hanno Klein
30 May 2017 1:02pm
The field was introduced for SEFs in order to distinguish “required” from “permitted” transactions. It does not identify “SEF” as such. There are no values for CFTC, SEC or others at this time as there are no specific requirements for it. This includes ESMA and MiFID/MiFIR. From the viewpoint of the regulator I guess they define anything sent to them to comply with their mandate or rule.
Are you aware of a requirement that could be addressed with 2347?
Robert Mitchell
30 May 2017 1:29pm
It’s just that FIXimate states “Swap Execution Facility (SEF) required transaction
The transaction is a “Required” transaction under Dodd-Frank Act SEF Rules. “Required” transactions are subject to the trade execution mandate under section 2(h)(8) of the CEA and are not block trades.” So if we had a MiFID2 SEF-required transaction would we use that same value or not use the field at all, or use a custom value? Perhaps it’s just the value description in FIXimate that’s throwing me off.
Hanno Klein
30 May 2017 1:56pm
I am not aware of an obligation to tag transactions as “SEF-required” under MiFID. Dodd-Frank requires it and FIXimate added this capability with EP176. It is only applicable to MiFID if ESMA would require the same distinction. So you do not need to use the field unless the applicable regulatory reporting regime requires it. FIXimate reflects business and regulatory requirements, i.e. there is always a source to motivate an extension. There may be one for your use case and then we can extend the protocol accordingly.
Robert Mitchell
31 May 2017 12:45am
Thanks for the response. Since our venue offers both CFTC and MiFID2 regulated instruments it just may seem odd to have a RegulatoryTransactionType but not have it set for MiFID2 instruments. We can probably just use a value > 100.
Hanno Klein
31 May 2017 1:51pm
You could join one of the MiFID working groups to propose additional standard values. That is where most of the extensions for MiFID are being discussed and proposed. Due to its regulatory nature the field RegulatoryTransactionType(2347) is not a union datatype with Reserved100 and hence does not allow user-defined values.
You could also use the Parties block and include an instance with PartyRole=68 (Host CA) or 69 (Home CA) to identify the competent authority in charge of the specific transaction in terms of reporting.
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Robert Mitchell
1 June 2017 3:12pm
I’ve requested membership. Waiting on response. Thanks for your work here in the forums.