Question 3.1.17

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Question 3.1.17

REMIT Implementing Act Article 5(1)(b) and Annex, table 1 data field 31 (Unique transaction ID), table 2 data field no 11 (contract ID).

We understand that market participants need to agree on their method of generating a Contract ID – this can include using the UTI algorithm provided by ACER. However, what should a MP do if its counterparty provides the ID after T+1 or T+30 or indeed not at all and they have not agreed to use the ACER algorithm? This is particularly of concern as the use of the ACER algorithm is not mandatory.

Under REMIT, phase 2 transactions need to be provided either under table 1 (for contracts that specify and outright price and volume) or under table 2.

In submitting a table 1 or 2 report the UTI field must be completed. However, it is possible a counterparty, who is not using the ACER algorithm, may not provide their UTI to us to enable us to report in the necessary timescales.

We are engaging with our CPs to ensure this does not occur but it is always a risk.

Our preferred approach is to:

1) Submit a temporary UTI, calculated based on the ACER algorithm.

2) Once we have received the UTI from the CP an ‘error’ report will be submitted to remove the previous report and a ‘new’ transaction report with the correct UTI will be submitted.

As an alternative to 2) we are also happy to simply submit a modify report if that is preferable to ACER.  Can ACER please confirm this is acceptable?


Answer

Market participants should submit a temporary UTI (in Data Field No (31) Unique transaction ID) in the new ‘N’ record, then once they have received the UTI from their counterparty, a ‘Modify’ report will be submitted to modify the previous report recalling the old UTI. In the Modify report, Data Field No (31) Unique transaction ID should be populated with the new UTI and “AdditionalUtiInfo” field in the schema should be populated with the old (temporary) UTI.

This type of UTI update is possible only for Bilateral trades, i.e. Table 1 with Organised Market Place ID=XBIL.

 

Using Schema Table 1_Version 2

1st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI123</uniqueTransactionIdentifier>

<actionType>N</actionType>

2st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI456</uniqueTransactionIdentifier>

<previousUniqueTransactionIdentifier> UTI123

</previousUniqueTransactionIdentifier>

<actionType>M</actionType>

 

Using Schema Table 1_Version 1

1st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI123</uniqueTransactionIdentifier>

<actionType>N</actionType>

2st report Using Schema Table 1_Version 1

<uniqueTransactionIdentifier>UTI456</uniqueTransactionIdentifier>

<additionalUtiInfo> UTI123 </ additionalUtiInfo>

<actionType>M</actionType>

The above option is not possible when reporting trades executed on an Organised Market Place and non-standard contracts reportable with Table 2. In Table 1 (for trades executed at an OMP) and Table 2 ‘Modify’ cannot be applied for amending the UTI and Contract ID respectively. Action type ‘C’ for ‘Cancel’ has to be used instead. For further information, please refer to Annex VII to the TRUM.

Updated: 
30/06/2020