The FCA has published Guidance Consultation 14/2: Consultation on version 3.1 of the Transaction Reporting User Pack (TRUP) (GC14/2).
The current version of the TRUP was published on 1 March 2012 and is known as TRUP 3. Following queries from firms and some on-going transaction reporting issues, the FCA is taking the opportunity to consult on changes to TRUP 3. The revised version, once finalised, will be known as TRUP 3.1.
The FCA proposes to make certain changes to TRUP 3 and these are intended to clarify:
- the use of ‘INTERNAL’ in sections 7.18.2, 9.3 (aggregated transactions) and 9.4 (average price transactions) and clarification that a firm must transaction report such that its change in position, and that of its client(s), is correct;
- section 9.1 that a firm hitting its own order on a trading venue should transaction report the resultant transaction;
- section 4.3 and reporting by firms that rely on the Liffe feed;
- section 7.15 concerning how the unit price should be reported for different instruments;
- section 7.19.1 and reporting the venue; and
- section 10 (particularly section 10.1) and the steps a firm should take to comply with its obligations under SYSC.
The FCA is also proposing to correct certain minor errors and update certain references in TRUP 3. This includes updating section 8.2.1 and correcting minor inaccuracies in the guidance on reporting transactions on Aii derivative markets conducted through clearing platforms of the market.
The proposed changes to TRUP 3 are set in red in Annex 1 of GC14/2. Additions are shown in underlined text and deletions are struck through. The clean text following the proposed changes for these sections is also set out in Annex 2 of GC14/2. Only those sections of text proposed to be changed are included. All other text in TRUP 3.1 will remain unchanged.
The deadline for comments on GC14/2 is 4 July 2014.