In case a market participant, which is trading at several organised market places, wants to have a consolidated view of all records of transactions, including orders to trade, how can this be achieved other than reporting through one single RRM?
Answer: Rather than selecting one single third-party RRM for their reporting services to the Agency, market participants could benefit from the above-mentioned relief of taking reasonable steps if reporting through organised market places, as an RRM, or through a third-party RRM selected by the organised market place concerned. Since RRMs are obliged, under the Agency’s RRM requirements, to share all data reported to the Agency with the market participant on their request, the market participant could choose one single third-party entity to collect any such already reported records of transactions, including orders to trade, from the various organised market places concerned in one consolidated way. This would also enable the market participant to report any life-cycle events through such single third-party entity and would enable them to build on the relevant reference IDs from the reports provided by the organised market place concerned to the Agency. Thus, with all necessary information from the organised market place concerned being provided through the single third-party entity, the reporting of lifecycle events can be linked to the originally reported information from the organised market place concerned. This can also include the information on the third party beneficiary.
Accordingly, for compliance purposes, the market participant may select a third party to collect all information reported by its different organised market places as RRMs in order to monitor the reported data through one single tool. But such compliance monitoring tool should not be confused with changing the reporting channel to the Agency.
As described above, the Agency believes that the reporting of organised market place data through the organised market place concerned, or through a third-party RRM selected by the organised market place concerned, is the best way to ensure the necessary completeness, accuracy, timeliness and data quality for market monitoring purposes (‘single order book’) and the market participant is relieved from taking further steps necessary in order to verify completeness, accuracy and timeliness of the data submitted to the Agency to a minimum necessary.