If 'alpha' trades identified by the UTI generated by the OMP are reportable under REMIT (if not reported under EMIR) then do the lifecycle events of the 'gamma' trade qualify as eligible for reporting, if so how is the UTI of the 'gamma' trade linked and is the Clearing Broker expected to report their side?
The Agency has already provided its understanding in Annex III to the TRUM, according to which clearing brokers do not have reporting obligations under REMIT for their clearing activity. The UTI of the transaction executed at the exchange may be different than the UTI of the back to back transaction reported by the executing broker (or other member of the exchange) and their clients. Still, both transactions should indicate the Organised Market Place they were originating from.
Executing Brokers can report their transactions in two ways:
- reporting two trade reports: one trade executed on the exchange and one trade as a back-to-back transaction with their client; or
- reporting one trade report: one trade report which includes their client information in the Beneficiary ID field (8) if the client is a REMIT market participant.