What we consulted on
In May 2014, we consulted on changes to the guidance for transaction reporting set out in the Transaction Reporting User Pack (TRUP) (GC14/2).
The Transaction Reporting User Pack (TRUP) provides guidance to firms on understanding the transaction reporting obligations that come from Directive 2004/39/EC on the Markets in Financial Instruments Directive (MiFID), implemented through SUP17 of the FCA Handbook.
Version three of the TRUP was published in March 2012 following a consultation of the entire text.
In response to some queries from firms and some ongoing transaction reporting issues we sought to clarify existing guidance, proposed some changes to the text, and corrected some minor errors.
What we clarified
The areas we sought to clarify were:
- that 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
- that a firm hitting its own order on a trading venue should transaction report the resultant transaction
- how the unit price should be reported for different instruments
- how to report the venue for a transaction
- what we expected for transaction reporting arrangements within firms
Response to feedback received
We have considered the responses and are now publishing finalised guidance, along with a summary of the feedback received. Overall there was support for the clarifications and in some cases we have provided additional clarification and examples. We have also taken the opportunity to update links and references and make editorial improvements to the text.
Version 3.1 of the TRUP will be effective immediately, with the exception of the guidance introduced in sections 7.5. Trading capacity, 7.18.2 Use of ‘INTERNAL’ and 9.1 Internal transactions, which will be effective from 6 August 2015.