Who has the reporting obligation for lifecycle change in case of standard contracts reported by OMPs? This question is significant for broker contracts.
In our view, the MP has the obligation for reporting all data – ‘new’ Orders, Contracts and Trades as well as any changes to the original report that arise from reporting errors or changes to the underlying data due to lifecycle events. However MPs can delegate reporting to OMPs but the OMP may not have sight of lifecycle events for trades that occur after the reporting day, say a partial novation of a trade. In this case any change to the originally reported information submitted as part of the reporting of a ‘new’ trade, will have to be reported by the MP (via an RRM), or possibly uploaded to the originating OMP and reported by them, should they offer such a service.
The obligation and responsibility of correct reporting lies with the market participant. Market participants should ensure that they can make changes to existing reports in an appropriate way. The Organised Market Place should offer a data reporting agreement for trades executed on their platforms. Such a reporting agreement may or may not include the possibility to update lifecycle events that occur outside the venue.
Market participants should be able to provide the Agency with information about any changes to the underlying data due to lifecycle events. They shall do so through third party Registered Reporting Mechanisms (RRMs). The list of (RRMs) is available on the REMIT Portal.