GC14/2 Consultation on Version 3.1 of the Transaction Reporting User Pack (TRUP)

This proposed guidance relates to the following rules in the FCA Handbook: 

  • SUP17 of the FCA Handbook (Transaction Reporting)

The full guidance:  GC14/02 Revision of Transaction Reporting User Pack Version 3 (TRUP V3)

This guidance is likely to be of most relevance to authorised firms with transaction reporting obligations

Background to this consultation

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.

TRUP Version 3 was published in March 2012, following a consultation on the entire text.
In response to some queries from firms and some ongoing transaction reporting issues we are taking the opportunity to:

  • clarify some of our existing guidance and propose changes to the text of the guidance
  • correct some minor errors and update some references

Summary of the key issues

We clarify:

  • 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
  • transaction reporting arrangements within firms – making it clearer what steps a firm should take to comply with its SYSC obligations

We are also taking this opportunity to correct some minor errors and update some out of date information (see section B of the main consultation text).

Cost benefit analysis 

Cost benefit analysis is not required given the scope of the changes.   

Please email your responses to: tmu@fca.org.uk

Please respond by Friday 4 July 2014 (two month consultation period)

Or send your responses to:

Markets Reporting Team
The Transaction Monitoring Unit
The Financial Conduct Authority
25 The North Colonnade
London E14 5HS
Telephone: 020 7066 6040