FAQ Question 3.1.17 states that for a Phase 2 reports in the Table 1 format that a change in UTI may be implemented through a modification of the existing report using either the for the Version 1 schema or the < additionalUtiInfo> field in the case of the Version 2 schema. The following question has been raised: For Table 1 Phase 2 reports is this process mandatory, or can the Phase 1 Table 1 process of erroring out the first report and resubmitting a new report with a new UTI (without a link to the previous UTI) be used as an alternative process?
Practical example: a new Phase 2 Table 1 report is successfully submitted by an MP but subsequently they wish to correct the UTI after discussion with the counterparty. They submit a report for that UTI with ActionType = "E" and they then submit a new report for the same deal with a new UTI (matching the counterparty's UTI) with ActionType = "N", they do NOT include any information about the original report or its UTI in the newly submitted report. Is this an acceptable process for correcting the UTI?
Market participants should clearly distinguish the Error “E” from the Modification “M” case. As indicated in the TRUM, “E” for Error should be used to denote a invalidation of a wrongly submitted report, while “M” for Modification should be used for reporting the modification of the details of a previously reported contract.
In order to correct the UTI that was wrongly submitted, the original report needs to be invalidated with Action type “E” and a new report with a new UTI (matching the counterparty's UTI) has to be submitted for the same deal with Action type “N”. The new report does not have to include any information about the original report or its UTI, since the original report was wrongly submitted in the first place.
However, with regards to Question 3.1.17 of the FAQs on REMIT transaction reporting, if a market participant’s counterparty provides the UTI after T+1 day or T+1 month, or alternatively not at all, the market participant who is reporting its reports should submit a temporary UTI. Once they have received the UTI from their counterparty, a ‘Modify’ report should be submitted to modify the previous report, recalling the old UTI.
If a report is due to be reported on a T+1 day basis, all life cycle events related to that report have to be reported on a T+1 day basis. Otherwise, if a new report is due to be reported on a T+1 month basis, all life cycle events related to that report have to be reported on a T+1 month basis. Examples of ’modification‘, ‘early termination’ and ‘error’ reports are available in Annex II to the TRUM.
For further information, please refer to Annex VII to the TRUM.