What is the current consenus on passing Transaction Reporting Venue (tag 20073) from Brokers to Clients ? There has recently been some rumour about this tag being downgraded as not Mandatory given the difficulty in populating this for complex booking scenarios.
In addition, the absence of this tag in the Transparency WG - FIX tags for MiFID2 post trade transparency Client-Broker.docx gave the impression that this is no longer being recommended. However as this document is for Post Trade Transparency can somebody confirm whether for guidance on Transaction Reporting Venue, we need to look at the TransReporting_1.3_22Jun17.pdf titled “MiFID II/R Implementation Guidelines for Inter-Firm Data Communication for Transaction Reporting” even though that document is still in Draft state?
I do not know what the consensus in the community is. However, I wanted to point out that 20073 is only the user-defined field for those users that cannot support standard repeating groups as follows:
PartyRole(452) = 73 (Execution venue)
PartyIDSource(447) = G (MIC)
PartyID(448) = <MIC value or “XOFF”)
The repeating group should be used instead of the user-defined field whenever possible.
I had only indicated the tag 20073 as an illustration as in most discussions it is easier to use the flattened tag rather than the repeating group.
My query was if the FIX Community is still recommending Brokers to support this tag for their clients. There has been no further updates if the Inter-firm communication between firms for Transaction Reporting document has been finalised.
Hi Hanno, One of my vendor raised a concern on what we are sending in 20073. Could you clarify if there is any difference between Operating MIC and SI MIC ? what should ideally a non-SI broker/firm send in this tag to the clients ?
User-defined tag 20073 PartyIDExecutionVenue (or better standard tag 452 PartyRole with valid value 73) conveys a venue of execution and suggests to do so by means of a MIC. An excerpt of the regulatory text is as follows “Use the ISO 10383 segment MIC for transactions executed on a trading venue, Systematic Internaliser (SI) or organised trading platform outside of the Union. Where the segment MIC does not exist, use the operating MIC.”
The fact that the venue is also an SI does not play a role for 20073, it is simply a MIC and the SI registers it either as an operating or segment MIC. If you want to expressly convey the fact and identity of an SI then you can use PartyRole 63 (Systematic Internaliser) to do so. But I guess this is not the given use case here.
Thanks for your response.
Some client/vendor do not accept Operating MIC, an alternative is to use XOFF. But the understanding about XOFF is trades done off the market. So the challenge remains for non-SI firms, what exactly to send in 20073 .
I think ESMA is quite clear in its definition of XOFF, i.e. it cannot be used if the execution does not conform to the definition:
Identification of the venue where the transaction was executed.
Use the ISO 10383 segment MIC for transactions executed on a trading venue.
Where the segment MIC does not exist, use the operating MIC.
Use MIC code ‘XOFF’ for financial instruments admitted to trading or traded on a trading venue, where the transaction on that financial instrument is not executed on a trading venue, systematic internaliser or organised trading platform outside of the Union.
Use SINT for financial instruments admitted to trading or traded on a trading venue, where the transaction >on that financial instrument is executed on a Systematic Internaliser.
You do not say on what basis an operating MIC is “not accepted”. Is it a technical reason? The transaction reporting guidelines developed by the FIX Regulatory subgroups contain examples where 20073 is optional but that is not the case in general.