Change Summary

Background

Several regulatory changes are being introduced that require small additions to the Whisperer API:

  1. The United Kingdom Temporary Permissions Regime (TPR) enables relevant EEA firms and funds who were using the passporting regime to transition to the UK full regulatory regime. This ends at the end of 30 December 2023 and consequently FXall and 360T are both establishing UK MTF platforms.
  2. As of 28 January 2024, phase II of the CFTC rules rewrite will require reporting parties to submit a Unique Product Identifier (UPI) on all executions reported to Swap Data Repositories (e.g. the DTCC).
  3. As of 29 April 2024, the recently conducted EMIR Refit will take effect, requiring European participants to include a new Report Tracking Number (RTN) in their transaction reporting.
  4. As of 30 September 2024, participants in the United Kingdom will fall under similarly updated reporting requirements for RTNs.
  5. Support for the MiFID "ExemptedDueToESCBPolicyTransaction" flag. Transactions entered in to by members of the European System of Central Banks (ESCB) are exempted from publication, as per ESMA RTS2, Article 14(1), and Article 15(1).

In addition, the Whisperer API is being extended to better support unsolicited (i.e. initiated by the venue, not the client) order-cancel events.

Affected Venues

  • All venues.

Change

An incremental (backwardly compatible) version change (v18945) is being deployed through all UAT and PROD environments in order to support the above changes.

Details of the changes are documented in the pages below:

Timeline

  • 09 December 2023 - UAT 
  • At client discretion - PROD

Whisperer Client Impact

SBE Clients

SBE Clients will not need to make any changes to support the new schema, until such time as they need to consume or publish UPI/RTN values.

FIX Clients

A new flag for the UK MiFID regulatory regime has been appended to the RegulatoryBodies space-delimited MultipleCharValue field. FIX Clients should:

  • Verify that they are able to correctly process the modified field in inbound messages sent by Whisperer, now expanding in size from the current five flags to six (i.e. from 9 to 11 characters).
  • If the client does not make changes to deliver the additional flag in their outbound messages to Whisperer, it's absence will be interpreted as 'N'.

Change Details

The new schema contains the following additions:

  1. BodyRegulatoryKey - new enum value MiFIDExemptedDueToESCBPolicyTransaction. Support for this value will be added in a future release; impacted venues: ebs_market_ilink3_sbe, fxspotstream, jpmorgan_fx.
  2. BodyRegulatoryKey - new enum value UPI. Support for this value will be added in a future release; impacted venues: here..
  3. LegRegulatoryKey - new enum values LegUPI and LegEMIRRTN. Support for these values will be added in a future release; impacted venues: here.
  4. RegulatoryBodies - new enum value UKMiFID. Support for this value will be added in a future release; impacted venues: t360_tex_maker, fxall_quicktrade_maker.
  5. ExecutionReport ExecRestatementReason - new enum values to better support communication of an unsolicited cancel. Support for these values will be added in a future release; impacted venues are yet to be confirmed.


Clients should additionally familiarise themselves with the following Pending Client System Impacts notices:

Documentation