We assume that it is always the exchange member who is considered to be the market participant and therefore reported as counterparty. This includes those exchange members that do not use their membership for prop trading, but to provide DMA to their customers.
In such a setup, what would be the status of such a customer?
Would he also be considered a market participant?
If this is the case, he would also have a reporting obligation. How would this be fulfilled?
Can we assume that this customer would not need to report transactions in the standard format (because this is what the exchange member already does)?
Does this mean that the customer would need to report non-standard transactions, with the exchange member being the other counterparty?
We assume that a customer, who is not an exchange member, but trading via DMA of an exchange member, is also considered a market participant.
Reporting of the exchange trade in the standard format will be done for the exchange member. The customer will need to report a second transaction in the non-standard format.
From the Agency’s point of view, this question is already addressed in the TRUM and explained into detail in Annex III to the TRUM available on the REMIT Portal.
Last update: 16/11/2015
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