Hello, A post trade question.
I’m looking at trades executed under both DF and ESMA regs, so I want to send the Executing Venue Type and Jurisdiction twice. Am I allowed to do this, or will parsers have issues with 452=73 appearing twice?
Syntactically this looks ok to me.
448=SEF
447=D
452=73
802=1
523=DoddFrankAct
803=4023
448=OTF
447=D
452=73
802=1
523=ESMA
803=4023
Thank you.
HI Mark,
Syntactically this is correct. It’s more the issue if your counterparty who is receiving this able to handle having two PartyRole=73.
Cheers,
Lisa T.
Hi Mark,
You should be able to do so and there shouldn’t be any issue. You can have the same value for tags multiple time. You just need to make sure that you are following proper sequence within repeating group.
Syntax is fine but semantic is not. Party role 73 is for the execution venue which is to be identified by a MIC (447=G) if it exists. However, you chose generic names (SEF, OTF) representing categories of execution venues and not actual venues. Understandably, there are no MICs for categories, hence you chose 447=D.
Semantically, using party role 73 twice means that your trade was executed on two different execution venues which is not what you want to express. You want to express that a trade on a single venue is subject to two different regulatory regimes. Hence you only need one party with two party sub IDs, one for DF and one for ESMA. However, I assume you expressed that the venue category is a SEF under DF and an OTF under ESMA regulations. Again, party role 73 is not about an “Executing Venue Type” as you termed it.
My advice would be to use the MIC of the actual venue and to use the standard party sub IDs 62 (Reporting obligation jurisdiction) and/or 63 (Voluntary reporting jurisdiction) to convey DF and ESMA. I am guessing that 62 applies here. These sub types were added with EP169 (EP169 CFTC Parts 43/45 Phase 2 – Commodity Swaps – FIX Trading Community v2.1) in the context of CFTC OTC Derivatives Regulatory Reporting for Parts 43&45. Their elaboration is: For a trade that falls under multiple jurisdictions this may be used to identify, through PartySubID(523), the reporting jurisdiction to which the party is obligated to report.
448=<MIC of actual execution venue>
447=G
452=73
802=2
523=“DoddFrankAct”
803=62
523=“ESMA”
803=62
There is also a field RegulatoryTransactionType(2347) which was added with EP176 (https://www.fixtrading.org/packages/ep176/) in the context of fixed income and Dodd-Frank. It could also solve your issue but currently only covers SEFs. It is part of the ER and TCR message.
Hi Lisa & Hanno,
Many thanks for the replies, your guidance is very much appreciated.
Regards Mark
Would this still be classed as valid if tag 453 (NoPartyIDs) was not present and tags were being repeated?
For Mark’s initial post I would also expect to see 453=2
In a word “No”. The <Parties> tags are only valid within the repeating group started by NoPartyIDs(453). The receiving FIX engine would (should) reject the message for “Invalid tag” as soon as one the <Parties> tags appears outside the component.
The rule stated by @deankauffman relates to tag=value encoding. For example, NoPartyIDs(453) is never present when using FIXML as encoding.
Thanks for confirming my thoughts