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These 13 Currencies comprise the 13 most liquid currencies (excluding the Korean won, which is a restricted currency) of the set of 17 currencies settled on CLS.

Summary

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  • Makers must provide a Market Mid Rate on FX NDF quotes.
  • Makers may need to provide a Market Mid Rate on FX Blocks, FX Swaps and FX Forwards quotes. This will be either be because they cannot meet the terms of the no-action letter noted above, because the quote is for an illiquid currency pair, or because the FX Block or FX Swap includes a non-deliverable component.
  • Makers do not need to provide a Market Mid Rate on FX ON, TN and Spot quotes.

Requirements

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  • Allow Makers to compute and store the Spot Market Mid Rate on all quotes for all product types.
  • Allow Makers to compute and store the Fwd Market Mid Rate on all legs for all quotes for all non-Spot product types.
  • Where venues allow, the computed Market Mid Rate must be included in the Maker's pre-Deal quote stream.
  • The Market Mid Rate values associated with the traded Quote will be stored alongside the Deal details for every requested transaction. NOTE: This is in addition to the Market Rate information prevailing at time of execution, which is also captured.

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The concept of a Unique Trade Identifier (UTI) is similar to the Unique Swap Identifier (USI) which is required for CFTC reporting ( US Dodd-Frank regulation), but is nevertheless more complicated as – under EMIR – both parties report whereas for CFTC the USI is issued by the reporting party on the transaction.

MiFID II

Brief History

The Markets The Markets in Financial Instruments Directive (commonly referred to under the acronym Directive (MiFID) is a legislative regulation directive, composed by the European Union (EU) on the basis of advice provided by the European Securities and Markets Authority (ESMA). The directive is intended for application by the European Member States, their regulatory authorities, and financial firms and institutions registered within the European Economic Area (EEA). The legislation is for:

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MiFID first appeared on the UK statute book from November 2007. However, in light of the financial crisis of 2008, the legislation went under additional revision ("MiFID II") to strengthen what was seen at the time as the failures of woefully lax regulations. The revisions to the original MiFID legislation are scheduled to take effect on 03 MiFID II took effect on 03 January 2018, with the new legislation being named MiFID II.

The MiFID II Framework

MiFID II contains a framework separated into two parts, the :

'level Level 1' framework was   - established in 2014, and contains the following areas:

  • a revised MiFID
  • The Markets in Financial Instruments Regulation (MiFIR)

Level 1 can then be supplemented by 'Level 2' supplements this with a number of implementing measures, (referred to as 'level 2' legislation) These measures which take two forms;

  • 'Delegated acts', drafted by the European Commission (EC) on the advice of ESMA
  • 'Technical Standards', drafted by ESMA and approved by the EC.

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MiFID II establishes provisions that the author's state are aimed to ensure that theat High-Frequency Trading (HFT) does not have an effect on market 'quality or integrity' by implementation of the following requirements:

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  • MiFID II authorised firms will be required to report to report transactions, providing complete and accurate details for financial instruments to the competent authorities directly, through Approved Reporting Mechanisms (ARMS) or the trading venue. 
  • Further, under article (50) MiFID II requires clock synchronisation for requires clock synchronisation for trading venues and their participants, . MarketFactory as a connectivity provider, synchronise clocks it's clocks in each data centre to ensure straight through compatibilityalso has obligations in this regard. Refer to Time Management for more detail.
  • MiFID II also introduces a requirement for firms and/or entities wishing to provide a Data a Data Reporting Service as Service as a business offering, to be authorised by the local authority (in the case of the UK this is the FCA).

MarketFactory along with other venues and market participants needed to support a series of new fields for reporting purposes, that include the following;

Personal Identification

Execution/Investment Decision Maker (EDM/IDM) values reference Personally Identifiable Information (PII)

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details previously registered by the market participant to unambiguously identify the one person considered to have primary responsibility for the transaction.

Under MiFID II, firms must report and record these details as MiFID II requires firms to report and record personally identifiable information (PII) as part of their record-keeping and transaction reporting obligations.

Entity Identification

The key Entities involved in a transaction include the following:

  • Maker
  • Taker
  • TOB Firm / Account
  • Reporting Entity
  • Prime Broker

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Thee are typically identified for regulatory reporting purposes via Legal Entity Identifiers (LEIs) and Market Identification Codes (MICs):

Waivers and Flags

  • New Orders (New Order Singles)
    Venues use  Legal Entity Identifier (LEI) - firms will not be able to execute a trade on behalf of a client who is eligible for a LEI and does not have one.
    Execution Venue MIC (A market identifier code which is unique in its ability to identify securities trading exchange).
    Pre-Trade Waivers and Flags (Used for orders that are large in scale, held in an order management facility pending disclosure, actionable indications of interest in request-for-quote waiver indicators are likely to be the illiquid instrument and the specific size).
  • Quote Messages (Snapshots and Incremental Refresh)
    New fields may include Execution Decision Maker containing the decision maker and likely to contain the algo shortcode, this field will be mandatory for in-scope products.
  • Outbound Executions (Execution reports)
    Must contain a LEI
    Execution Decision Maker
    Algorithmic Order Flag, set if the order was algorithmic.

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