The Global Technical Committee has reviewed and preliminarily approved the ESMA RTS 22 Extension Proposal. This document seeks to address a gap in the FIX Protocol Application Layer to fulfill requirements for the ESMA RTS22 which addresses post-trade transaction reporting data requirements and obligations when reporting transactions to ESMA or National Competent Authorities (NCA).
The document now enters a public comment period in which public review and feedback is encouraged. Once the public comment period closes, the Global Technical Governance Board will meet to review public comments before final approval.
Please post feedback, comments, and questions as replies to this discussion thread.
A link to the proposal can be found at: http://www.fixtrading.org/packages/fix-protocol-ga-esma-rts-22-extensions/
The public comment period ends on July 11, 2017.
POSTED BY: Hannah Wright
28 June 2017 7:33am
General Comments
- Does this proposal extend to Real List (35=E) and Multi-Leg Orders (35=AB)
Trading Venue Transaction ID Code --> In the AFME FIX Working Group they are proposing ExecID<17> is that also an option?
Trading Date and Time --> In early extension packs the existing TransactTime<60> was extended to hold the additional precision (up to Nanoseconds). Using a repeating group for a timestamp feels over engineered.
In the event that one party does not support repeating groups, what is the flattened alternative? Will it be TransactTime<60>
Trading Capacity - we have concerns about re-using enumerations with a MiFID II meaning, which we have conveyed separately.
Instrument Identification Code --> We feel other identifiers are more appropriate for trading. It is only on the transaction report that ISIN needs to be sent to the regulators. We should leave the ID source as blank here and leave existing process between buy-side and sell-side to determine what identifiers they use.
Investment Decision within the firm - what are the flattened tag alternatives
Execution within firm - what are the flattened tag alternatives