Change Summary

Background

360T will decommission Unique Swap Identifier (USI) from all 360T APIs on the 17th of March 2025.

Affected Venues

Change

360T will remove the USI value (the 10-digit prefix “1010000281” followed by a unique transaction ID) from all 360T platforms/ APIs.

To comply with the CFTC Rewrite Phase 1 regulatory requirements, 360T replaced USI with Unique Transaction Identifier (UTI) in December 2022. While the clients trading in the SEF trading facility adapted to the CFTC Rewrite regulatory requirement changes in December 2022 and started to consume/ disseminate UTIs, clients trading on MTF (EU and UK) were already using UTIs to report trades. The change in regulatory requirements made USI redundant.

Timeline

10 Feb 2025 - UAT - No support for USI in all 360T APIs and platforms.
14 Mar 2025 - UAT - Whisperer release 2025.03.XX.WE will be available for clients to ensure the client systems can handle the changes introduced by MarketFactory to process venue RegulatoryTradeIDs as a UTI and not a USI.
17 Mar 2025 - PROD - 360T to decommission USI from all APIs and platforms.
At client discretion - PROD - MarketFactory will process RegulatoryTradeID from 360T as a Unique Transaction Identifier (UTI), not a Unique Swaps Identifier (USI).

Whisperer Client Impact

Change Details

Whisperer clients trading on 360T SEF venue will see the following changes:

t360_gtx - Support for LegSEFUSI in LegRegulatoryFields will be dropped.
t360_tex_maker - Whisperer clients trading on the SEF venue will start to receive LegEMIRUTIPrefix and LegEMIRUTI and will not receive LegSEFUSIPrefix and LegSEFUSI in the ExecutionReport. Clients will receive AllocEMIRUTIPrefix and AllocEMIRUTI instead of AllocSEFUSIPrefix and AllocSEFUSI for SEF trades with allocations.

In addition to the aforementioned changes,

t360_tex - Will accept SEF requests from Whisperer clients. The venue UTI value for SEF trades will be handled as LegEMIRUTIPrefix (LEI of the trading venue) and LegEMIRUTI (a Unique TradeID).

Based on the constellation of companies involved in the RFS negotiation and their configuration, 360T will deem a request SEF. The SEF trading conditions are:

Both requester and provider entities must be SEF-enabled
The requested product is in scope for SEF (NDF and NDS), and
The trading party is a US entity/ person. Trading on SEF is mandatory for US entities/ persons.