REMIT Reporting Services and Solutions - July 2015 updated March 2016
5.3.4
Multiple agreements
Those who trade with many OMPs, and who use them to report the data, will need to sign a data reporting
agreement with each, who will also have different offerings and pricing. This will lead to the need to manage many
contracts and relationships. There has been an attempt to introduce a “standard data reporting agreement” by
certain bodies, but it has not been universally adopted.
5.4 Different types of offering from OMPs
During the run up to 7th October 2015, OMP brought their offerings to market. These fall into several categories:
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Direct reporting
Upload service
Sending the data to an RRM
“Full” RRM
EMIR TR/RRM
5.4.1
Direct reporting
An OMP is obliged to offer a service to report data that arose from activity on their platform to ACER. In that
capacity, each OMP must somehow offer a direct service to each member of the platform to send the data to ACER.
The OMP may charge for this service, and may also delegate the service to another party to deliver. But the
agreement would be between the market participant and the OMP for data delivery and from February 2016 would
have the liability characteristics just described.
Generally the agreement would apply to data that arises on the platform, i.e. all order data, trade data that the OMP
has (not including beneficiary information) and also events that arise on the platform (which for broker platforms
excludes post trade events). However, some OMPs may offer to address these goals with their direct service, for
example offering a service, which permits the reporting of post trade events (which would need to be notified by the
market participant to the OMP).
There is no obligation to use the OMP’s direct reporting agreement so long as the market participant finds another
way to report, although the more recent ruling could make direct reporting more attractive. The previous section
examined the issues with using one or more direct services. The next section will also look at this topic.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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