We are being told that our logic to send reporting data should also consider the IDM "Our logic should support checking if EDM is a MiFID firm, if no, then check if IDM is a MiFID firm. If IDM is a MiFID firm then allow for this data to be sent as the executing firm’
If you have been asked this question, did you determine it to be true and recognize the IDM or was it determined the EDM should only be considered?
IDM is a concept that only applies to MiFID markets.
We had client opting to populate EDM with IDM if no EDM is explicitly given, but that was always a custom request as far as I know.
The rules for when and how to populate the IDM and EDM for transaction reporting are in RTS 22 articles 8 and 9 and we can’t comment beyond that. The FIX implementations are to use the Parties component - with fields as follows:
IDM:
Where this is a trader:
PartyRole(452) = 122 (Investment decision maker)
PartyIDSource(447) = O (National ID) or P (Short code identifier)
PartyRoleQualifier(2376) = 24 (Natural person)
Where this is an algorithm:
PartyRole(452) = 122 (Investment decision maker)
PartyIDSource(447) = D (Proprietary / Custom code) or P (Short code identifier)
PartyRoleQualifier(2376) = 22 (Algorithm)
EDM:
Where this is an algorithm:
PartyRole(452) = 12 (Executing trader)
PartyIDSource(447) = D (Proprietary / Custom code) or P (Short code identifier)
PartyRoleQualifier(2376) = 22 (Algorithm)
Where flagging “NORE”:
New OrderAttributeGrp component containing three fields, NoOrderAttributes(2593), OrderAttributeType(2594)=7 (Order execution instructed by client)
OrderAttributeValue(2595)="Y