Trade Flagging Obligation
Post-trade transparency refers to the trading venue's obligations to publish the relevant data of each transaction immediately or, according to the venue's deferred publication regime, at the end of a defined time period. For further reference see Post-Trade Transparency.
As part of the post-trade transparency requirements, EU regulation prescribes that the publication of trade messages must include the dissemination of trade flags that indicate what kind of price formation process led to the execution. Trade flags will, among other things, indicate whether full pre-trade transparency was available during the price formation process. They will inform on what kind of pre-trade transparency waivers prevailed for specific trades and what kind of deferred publication regime was applicable.
Each asset class is subject to different post-trade transparency regimes that are identified by different standard trade flags. Swiss Law does not deal with this topic.
SIX Swiss Exchange will adhere to the trade flagging standard FIX MMT v3.01. MMT stands for Market Model Typology. MMT flags embedded in public trade messages will provide market data consumers with the following trade details:
Market mechanism applied for the execution (CLOB, MMB, off book negotiated trade)
Trading mode for the execution (opening/intraday/closing auction, continuous trading)
Pre-trade transparency waiver applied (if any) for the execution
Deferred publication regime (if any) applied after the execution
SIX Swiss Exchange will launch a new datafeed for the dissemination of public market data in 2017. This new datafeed will provide all trade flags required by European regulation.
Art. 3-11 Transparency for Trading Venues
RTS 1: (equities) Draft Regulatory Technical Standards on Transparency Requirements in respect of shares, depositary receipts, exchange traded funds, certificates and other similar financial instruments
RTS 2: (non-equities) Draft Regulatory Technical Standards on Transparency Requirements in respect of bonds, structured finance products, emission allowances and derivatives
Q: While FIX MMT data model v3.01 looks straightforward for on-book executions, we are concerned about some risk of overlap and breach of mutual exclusivity in the off-book trade reporting area. Where can we find clarifications?
A: The FIX MMT working group has carefully analyzed the regulatory requirements. It came to the conclusion that FIX MMT data model v3.01 can cope with trade reporting scenarios and that the data model ensures trade flags' mutual exclusivity. Please refer to MMT documentation and corresponding FAQ on the FIX website for details.