05th December 2022

CFTC Rule Re-Write change was originally scheduled to go-live on the 25th May 2022 is postponed to 05th December 2022.

The CFTC has implemented a revision of the reporting rules, known as the CFTC ReWrite. It foresees the replacement of the USI with the standardized UTI in accordance with ISO 23897. The main purpose is to reduce complexity associated with reporting under different jurisdictions. SEF member clients will have to assure that they start reporting the UTI to the DTCC once the CFTC ReWrite becomes effective.

From the 05th December 2022, UTI/ TVTIC values will comprise LEI of the operating entity of a Liquidity Venue [360T/ FXALL for eg] and a unique venue assigned Trade Identifier.

• At present, UTI/ TVTIC values comprise a 10 digit prefix and a unique trade id. From the 05th December 2022, the length of UTI/ TVTIC values will increase by 10 characters since LEIs are 20 characters alphanumeric value. 
• Please note that the USI format will not change.

All venues offering On-SEF trading are in scope. However:

• The primary Whisperer impact is for Maker clients trading on ECNs.
• Taker clients trading directly with LPs typically do not receive UTI values via the trading connection.

MarketFactory has formally verified the planned changes for the following platforms:

1. BAML
2. Bloomberg
3. Currenex
4. ebs_market_mdp3_sbe_udp
5. Refinitiv
6. 360T