Question 2.1.5 Data Field (4)
This question pertains to exchange contracts traded on a broker. These contracts are typically traded anonymously, so that neither party to the trade knows who the other party is. The question is what value should be supplied for TRUM field 4 for trades on such contracts. An example would be a XXX Germany Baseload contract traded on broker platform.
We believe the counterparty should be omitted. This would be consistent with the rule that exchange-traded contracts do not require a counterparty.
If the trade takes place on an exchange with orders to trade placed on the broker’s screen or voice brokered, this trade should be reported as any other trade that takes place on exchange.
If traded on the broker’s screen, the orders should be reported as orders placed on the exchange’s contract. There is no expectation that the order report and the trade report are linked together as they were placed first and executed after on two different Organised Market Places.
When orders on futures traded on exchanges are placed on the broker platforms, e.g. Indication of Interest (IOI), Field (4) “ID of the of the market participant or counterparty” should include the ID of the Exchange.
This can be reported in the form of the LEI, BIC, EIC, or ACER code. When only the Exchange's MIC code is available to the reporting party, this can be reported (as a last resource) in the format XMIC0000.EU - where the 4 first digits represent the Exchange's MIC code, followed by 5 zeros, followed by ".EU" to replicate an ACER code.
For the reporting of the trades and orders, please see relevant the examples included in Annex II to the TRUM.