Question 3.2.2

Question 2.1.26 states that in case of backloading of standard contracts, in assigning a UTI this doesn’t have to match with the one reported by the other market participant.

Under the obligation to report non-standard contracts, there is the same issue with regards to the Contract ID for contracts that are subject to backloading.

Party A and Party B have to report a non-standard contract that is subject to the back loading requirement. As this contract was in existence prior to the entry into force of the obligation to report, a common Contract ID will not have been agreed and allocated to the contract. Does the same logic for the backloading of UTI in standard contracts apply?

Answer

Non-standard contracts that are subject to the back loading requirement under REMIT should be reported with a Contract ID, but there would be no expectation that the Contract ID adopted will match between the two market participants for back loaded contracts.

The Contract ID is required because otherwise the market participant will not be able to link the executions to the contract. The Contract ID can be anything the market participant would like to submit as long as it is unique to the market participant and does not need to match the Contract ID of the other market participant.