Hi,
May I get a feedback on everyone on the implementation of the tag 20063 (I am an SI). Is this expected to be returned on individual fill notifications (assuming we are are SI)?
From the MiFID II/R Trade Reporting Implementation Guidelines v1.6, we are expecting this to be returned only at order acceptance.
Please advise if there has been any change recently.
The guideline is focussed on trade reporting scenarios, hence a trade is the basis. The use case is not “order was accepted by an SI”. The SI execution only becomes relevant on a trade and I think it makes sense to recommend that individual fill notifications carry this information, rather than getting it upon order acceptance, having to store it and enrich trades with it every time the order is (partially) filled. What in v1.6 of the guideline led you to believe it could be only for order acceptance? Note that v1.7 was published a week ago on the FIX website (https://www.fixtrading.org/fix-and-mifid/mifid-implementation-guidelines/).
There is a use case for order level information, i.e. “order was submitted by an SI” which is covered by the OrderAttributeGrp with OrderAttributeType(2594)=5 (Systematic internaliser order). Firms who are unable to support repeating groups may use 8015 OrderAttributeTypes = 5 (if multiple values are required in this field they are to be delimited by spaces).
hi hanno, thanks for clarifying - it is on this section in page 18 on the document which is unchanged even on v1.7.
Brokers identifying themselves as SIs
A number of FIX members have requested that brokers identify whether they are an SI or not at the point of order receipt. The FIX implementation for this is to use the Parties6 repeating component as follows: PartyRole(452) = 63 (systematic internaliser) PartyIDSource(447) = G (MIC) PartyID(448) = the appropriate SI MIC
With the wording “at the point of order receipt”, we then made an assumption that this is returned at order ack execution report instead of trades. Should we consider changing the wording then?
Thanks for pointing out the language in the document and I think it is worth a clarification from the regulatory subgroups that are compiling these guidelines. My take was that it should read “A number of FIX members have requested that brokers identify whether they are an SI or not already at the point of order receipt and not only at the point of order execution.”. Once the broker has added the parties element to the order it can populate it on every ExecutionReport going out. It should not be additional effort to do that after the initial ExecutionReport confirming the receipt of the order.
Where do you see value if the sentence were to say “A number of FIX members have requested that brokers identify whether they are an SI or not only at the point of order receipt and not also at the point of order execution.”? Is there an issue with my assumption above? The FIX standard allows you to populate the parties block on any ExecutionReport.