On February 6, the Financial Conduct Authority (FCA) published an updated version of its transaction reporting user pack (TRUP).
The TRUP provides market participants (including FCA authorized firms, firms from non-EU countries trading on UK markets, and operators of an approved reporting mechanism or a regulated market or a multilateral trading facility) with guidance on transaction reporting obligations deriving from the Markets in Financial Instruments Directive (MiFID). The FCA had previously published a consultation on TRUP in May 2014, and the revised TRUP includes a number of clarifications based upon feedback received.
The clarifications include:
- The transaction reports a firm sends for its transactions must accurately reflect the change in position for the firm and its client(s) resulting from the transactions.
- A firm hitting its own order on a trading venue should report the resultant transaction.
- How the unit price should be reported for different instruments.
- How to report the venue for a transaction.
- What the FCA expects for transaction reporting arrangements within firms.
The revised TRUP is effective immediately, with the exception of the guidance introduced in sections 7.5 (trading capacity), 7.18.2 (use of the “internal” signifier to show trading activity wholly within a firm between different accounts) and 9.1 (with further guidance on internal transactions), which will take effect from August 6.
The revised TRUP is available here.
The FCA’s mark-up showing the changes made is available here.