DRAFT. Global FX Division Market Architecture Group (MAG) FX trade flows (ECN, SEF and Clearing Broker)
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1 DRAFT Global FX Division Market Architecture Group (MAG) FX trade flows (ECN, SEF and Clearing Broker) 1
2 SEF and Platform Majority of flow will remain on ECN and Single-Dealer Platforms Question if ECN will adopt SEF-like functionality If so, then should follow SEF workflow, if not, then should follow SDP flow Will SEF allow for dealers to act as 3 rd -party? Would dealers want the responsibility for SEF compliance? Objective to make platform trades the same flow SEF and ECN Major question on SEFs will be whether we continue to confirm or verify trades or if making SEF legal confirm means the existing confirmations process goes away 2
3 SEF Flow SEF Submitting Party Counterparty FXTR Execution USI Assignment Trade notification USI (mandatory) Trade notification USI (platform mandatory) Real-time, PET and Confirmation data (Platform USI) Real-time, PET and Confirmation (platform USI) Real-time, PET and Confirmation (platform USI) Trade confirmation / verification 3
4 Platform Flow Platform Submitting Party Counterparty FXTR Execution USI Assignment Trade notification USI (mandatory) Trade notification USI (platform mandatory) Submitting Party Trade (platform USI) Submitting party confirmation USI (mandatory) Counterparty USI (platform mandatory) 4
5 Brokered Trades Broker Submitting Party Non-Submitting Party FXTR Execution USI Assignment if voice to voice, USI consumption if platform to voice Trade recap USI (mandatory) Trade recap USI (mandatory) Submitting Party Trade (Broker USI) Submitting Party confirmation Broker USI (mandatory) Non-Submitting Party Broker USI (mandatory) 5
6 Prime Broker and Clearing Broker Flow Prime Broker flow, the PB steps-in to the trade to credit intermediate Clearing flow assumes agency FCM Variability in agency flow comes from when CB is notified of trade and if the EB USI is included workflow allows for either. Workflow does not include direct novationnotification to client via CCP, but this may convey CCP2 USI 6
7 Give-up and Principal Model Flows EB PB FXTR Client execution USI Assignment Note: Should the give-up be treated as a post-allocation swap and the PB client indicated as it would be on a block trade? EB-PB trade with EB USI FXTR Alleged Trade to NRP (recommended RP USI) EB trade w/eb USI PB step-in USI Assignment PB-Client leg PB-Client trade with PB USI Clearing Broker Flow PB-EB trade with EB USI (if dual reporting) 7
8 Clearing Broker Flow Client Executing Broker Cleairng Broker CCP FXTR Execution USI Assignment EB-Client bi-lateral trade (pre-cleared) with EB USI EB CCP submission Client trade is either submitted directly to the CCP or submitted via their clearing broker Or client submits via their Clearing Broker Either client direct CCP submission CCP Novation, 2 tickets CCP-EB, CCP-Client USI assign CCP-EB (CCP1) USI assign CCP-Client (CCP2) CCP-EB with CCP1, reference EB USI CCP-Client with CCP2, reference EB USI CCP step-in, CCP1 and EB USI Exit bi-lateral trade (EB USI), or amend original trade to face the CCP (EB USI and CCP USI) CCP step-in, CCP2 and EB USI (if previously communicated) CCP step-in, CCP2 and EB USI (if previously communicated) 8
9 Bi-lateral trading Language of model changed submitting party and counterparty Allows for discussion on USI using Dodd-Frank Rules and an International ID using separate set of rules inbilateral flow If the case, parties would act in both role of submitting party and as counterparty Amend now support two use cases Original case (cancel / new ) documented as an exceptions case Single message modify does not cause a USI change and thus is not documented For the case where the submitting party performs a cancel & new and their counterparty has not, the counterparty will need to scrape the USI from the confirm of the new and apply to their amendment record 9
10 Bi-lateral Execution Submitting Party Counterparty FXTR Execution USI Assignment Trade recap USI (recommended) Submitting Party Trade Report FXTR Alleged Trade to NRP (recommended SP USI) Non-reporting party trade report Submitting party confirmation USI (mandatory) Counterparty confirmation SP USI (recommednedif available from recap) USI upload Trade amend (USI update) or via Snapshot data 10
11 Trade Amendment (Exception Case) Submitting Party Counterparty FXTR Agree amendment Assign New USI Link original trade to New (recommended) Trade recap New USI (recommended) Submitting Party Cancel (original USI) Counterparty Cancel (original USI) Submitting Party Amend (New USI), reference original USI FXTR alleged trade to CP (recommended SP USI) FXTR alleged trade to CP (recommended SP USI) Counterparty trade Cancel Submitting Party confirmation of amendment New USI (mandatory), old USI (recommended) Counterparty amendment confirmation RP old USI (recommended) RP new USI (recommedned if available from recap or CP ACK) USI upload Trade amend (USI update) 11
12 Trade Novation Currently under review 12
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