Carl Erdly
19 May 2017 10:03am
Appreciating this is not FIX protocol-specific, I would be interested to hear different firm’s interpretation of the “person responsible” for Investment and Execution Decision Maker designations. Our internal discussions have thus far been centred around drilling down to the actual person who booked the order (IDM) and the trader who executed (EDM) but recent feedback from other industry participants hints at others identifying senior management - the head of trading or the chief investment officer for example - for these fields. Using more senior level people would make our PII data collection exercise much easier.
Would be interested in hearing your thoughts. Thanks!
Hanno Klein
19 May 2017 10:26am
Just a request for clarification: ESMA’s term “decision” only applies to the investment and not to the execution. Limiting it to senior management would then only apply to the investment decision.
RTS 24, Annex, Table 2, Field 4 Investment decision within firm (responsible for the investment decision)
RTS 24, Annex, Table 2, Field 5 Execution within firm (responsible for the execution)
Do you agree?
Carl Erdly
19 May 2017 10:34am
Agreed - guess the key word in both then is “responsible,” seeing as if the Head of Trading has individual traders working in his/her organisation, she / he is responsible for every execution completed by the team. So both IDM and EDM could be rolled up the management level in theory.
Silvano Stagni
19 May 2017 10:52am
The way I read RTS 22 and RTS 24 and their Annexes the person ‘responsible for the Investment decision’ could be Senior Management but the person ‘responsible for the execution’ is the person that actually organises the execution according to corporate policies for choices of venues, etc.