Question 2.1.26 Data Field (30)
The XXX trade matching system recognises two time stamps in the non-MTF trade execution process (which currently represents virtually 100% of screen trading in the physical energy markets).
The first is the time at which an order is aggressed and potentially matched. This time is recorded in the system as “time”. However, under the non-MTF trading workflow, the operator of the venue has to exercise discretion in respect of every transaction meaning that this is not the point of execution. Nevertheless, at this point in the workflow the order is removed from the trading screen and the time is printed to the market to show the initial match on a trade ticker.
The second time stamp (known as “execution time”) is the point of execution and which takes place when a broker for the trading venue matches the two orders and executes them in the system as a legally binding transaction.
Order initiated at 13:00:00
Aggressed at 13:02:00 - order removed from the market at this point and the market sees the potential trade in the ticker
Executed by a broker at 13:03:00.
The confirmation requested is that the second “time executed” time stamp is treated an internal administrative process and is not a reportable event.
From a market manipulation/market abuse perspective, the first time stamp - which indicates the moment at which an order has been potentially matched and shown to the market - is the more important.
It serves no useful purpose to publish the second “execution time” stamp and we cannot, in any event, see how that would be reported under the schema as there is no way to describe it. We would be sending a modify record with no fields modified.
Given the scope for misunderstanding and a disparate approach to time stamp reporting, we ask that ACER makes a clear statement about the time stamp which needs to be reported (i.e. the first initial match time).
Please see Field 30 “Transaction timestamp“ in the TRUM: “The date and time of the contract execution or order submission, or their modification, cancellation or termination.” . This should be understood as the time at which two orders match. In the above case we would expect to receive 13:02:00 in the timestamp field.
If reporting parties would also like to report <executionTime > to indicate that the legal execution time takes place a few second/minutes after the order have matched this can be done.
When <executionTime > is different than <transactionTime>, this can be reported under <executionTime></executionTime> code. For the example above: