Clarification on reporting of transactions related to OTC clearing on standard contracts registered at the exchange. Should the exchange report these transactions even though the volume and price related to the registered cleared transaction could not be necessarily related to a unique transaction executed on broker platform?
1) Market participant A executes on a broker platform a transaction with market participant B for a volume V1 and price P1 on day 15th of August.
2) On 17 August market participant A execute another transaction on a broker platform with the same market participant B for a volume V2 and price P2.
3) On 20 August Market participant A registers at exchange for clearing purpose a OTC transaction with market participant B for volume V=V1+V2 at price P (potentially different from P1 or P2).
We believe transactions registered at exchanges related to OTC clearing should not be reported to ACER, as the clearing could be referred to cumulated volumes and a price chosen by market participants and hence do not provide useful elements for market monitoring. Furthermore, such reporting could lead to a double reporting of the same transactions from two different parties (i.e. broker platform and the exchange).
From the above question, we understand that there are four separate transactions:
1) on 15 August volume V1 and price P1
2) on 17 August volume V2 and price P2
3) on 20 August the above transactions (V=V1+V2 at price P ) are terminated (this could also be split in two transactions)
4) and cleared at the exchange based on the new single transaction (V=V1+V2 at price P)
Please note that transaction (3) above, may be a termination or another transaction to offset transaction (1) and (2). There will not be any double counting.
Last update: 16/02/2016
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