REMIT Reporting Services and Solutions - July 2015 updated March 2016
5.3.1
Unknown data
Several of the fields that must be sent to ACER are not generally known by the OMP. The key such field is the
Beneficiary ID when the beneficiary is not the market participant (for example when acting as Agent). This is only a
problem when such trades are struck, and the issue therefore does not apply to all market participants.
5.3.2
Post trade events
Generally trades executed on a broker platform are then handed over to the counterparties once struck. This means
that post trade modifications and early terminations are not carried out by the broker, but between the
counterparties themselves. Since the broker will not be aware of these events, they will need to be notified to ACER
somehow. Some OMPs may offer the facility to make such notifications on their platforms and some will not, and in
any case, the counterparties may wish to report post trade events via a “full RRM”.
Those electing to use another platform to send initial executions to ACER, but not post trade events will face a
“timing issue” if they use another RRM to report the events. This can be summarised by the following diagram:
The issue is that if a post trade event occurs on the same day as the initial execution, it will not be clear whether the
OMP has reported. If the post trade event is then reported to the RRM, it may get rejected because the original
trade will not yet be registered in the ARIS system.
5.3.3
Reconciliation
Since this report was first written, ACER have issued an answer stating that if a market participant signs the data
reporting agreement of either the OMP, or their preferred RRM, the requirement to reconcile is relieved. However
those choosing to either report the data themselves via a third party RRM, or those who ask the OMP to “send” data
to a different RRM, will still have this requirement. Never the less, many will wish to try to use as few RRMs as
possible since it is still best practice to perform a reconciliation.
In addition, most of those who trade energy do not store their orders anywhere on their site, but will never the less
wish to keep a copy of the data that the regulator has about them, both to be able to “replay” what has happened in
the event of an investigation and also as a possible feed to a surveillance system.
Those who trade across many OMPs, and who use them to report, will find this data gathering process quite difficult,
since each OMP will make the data available in a different fashion.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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