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Table of Contents

Change Overview from 360T

At present, 360T distributes three different types of regulatory trade identifiers to trade counterparties, namely:

• USI (Unique Swap Identifier) generated for 360T SEF trades

• UTI (Unique Transaction Identifier) generated for the purpose of EMIR reporting

• TVTIC (Trading Venue Transaction Identification Code) generated for 360T MTF trades

The format of the above-mentioned identifiers was identical and consists of the 10 digits prefix “1010000281” followed by a unique transaction id.

The CFTC has implemented a revision of the reporting rules, known as the CFTC ReWrite. It was initially planned to become effective as of the 25th May 2022 and was recently postponed to the 5th of December 2022. It foresees the replacement of the USI with the standardized UTI in accordance with ISO 23897. The main purpose is to reduce the complexity associated with reporting under different jurisdictions.

In order to adhere with the ISO 23897 standard already with the coming release, 360T will adjust the format of the UTI and the TVTIC where the existing prefix will be replaced by the Legal Entity Identifier (LEI):

• "5493006UQP8F8P24HJ68" (LEI of 360 Trading Networks INC.) for SEF trades

• "529900P0204W9HA8JP36" (LEI of 360 Treasury Systems AG) for any other trade

Note: The USI format will not change.

This adjustment will be deployed onto the production systems as part of the Release 4.14 scheduled on the 14th of March 2022. The change can be tested in the Integration environment as of the 18th of February 2022.

Since the LEI consists of 20 alphanumerical characters, the length of the UTI and TVTIC will increase by 10 characters. Please assure that you will be able to cope with this change.

360T will continue to distribute the USI for existing API versions even after the 5th of December to not disrupt the functioning of existing interfaces and leave sufficient lead time for any changes required for concerned customers. If you are a 360T SEF member, you will have to assure that you start reporting the UTI to the DTCC once the CFTC ReWrite becomes effective.

Note
titleConformance/ Certification Testing

360T Integration environments are deployed with CFTC Rule Re-Write change since 18th February 2022.

MarketFactory have connected to 360T Integration environment and made sure the CFTC Rule Re-Write changes are in effect.

MarketFactory Analysis

...

titleConformance/ Certification Testing

...

360T-SuperSonicTex_FIX_MarketMaker_v1.9.0.pdf

MarketFactory does not yet support of NDF's in SuperSonic and thus no further analysis is done in this area. 

360T Integration environment for tex_maker has CFTC Rule Re-Write changes in effect.

Impact to MarketFactory

...

No changes required in MarketFactory gateway but will involve testing effort.

Note
titleImpact to Clients

Clients will see changes in values published in LegMiFIDTVTIC, AllocMiFIDTVTIC, LegEMIRUTI and AllocEMIRUTI as the UTI and TVTIC values will comprise Legal Entity Identifier/ LEI of the operating entity of a LP [360T in this case] and a TradeID.

The LEI value is a 20 characters alphanumeric value so the length of the UTI and TVTIC values will increase by 10 characters. Eg value: 529900P0204W9HA8JP3681409685.