Question 2.1.4 Data Field (3)
Is it mandatory for OTC contracts, to fill Table 1, Field 3? In the examples provided by ACER, such fields are filled only for standard contracts and examples 15.2-18.2. What features of examples 15.2-18.2 are triggers for reporting this field? What is the understanding of the person concluding the contract in case of OTC market? Is it a person whose signature appears on the contract?
In our opinion, this field should not be required for contracts concluded OTC.
Data Field (3) ID of Trader is required to be populated for any contract executed at organised market places and bilaterally as already indicated in the TRUM.
For executions executed under the framework of non-standard contracts, examples are available in Section (2) of Annex II to the TRUM. The Agency would not expect this filed to be reported in line with the examples provided in Annex II to the TRUM.