REMIT Reporting Services and Solutions - July 2015 updated March 2016
5.4.4
“Full” RRM
An OMP may elect to become a “Full” RRM, i.e. they will offer the service of standalone RRMs alongside meeting
their OMP obligations. They will accept orders and trades from any other OMP (whether sent directly or by the
market participant) and off venue data will also be accepted.
The full offering is provided together with one or more of the other offering types (the direct reporting offering is
mandatory in any case). It generally suits market participants who mainly trade on that OMP, but will also have a
certain proportion of other trades. However nothing precludes such an OMP being considered instead of another full
RRM. Some of these OMPs also offer “phase 2” off venue reporting.
5.4.5
EMIR TR/RRM
Some EMIR Trade Repositories also act as “Full” RRMs (although not all offer this service). These TRs have added a
service which allows them to act as RRM for any type of data under REMIT.
Using an EMIR TR/RRM suits those who have activity across a variety of jurisdictions. Data can be sent to the
“destination” no matter under which rule set it is found, and it can be routed to the appropriate destination. This
arrangement has several benefits, such as the reuse of a solid infrastructure already in production, “future proofing”
against new regulations, and also the ability to deal with one provider only.
Some such TRs/RRMs will also partner with OMPs and services in order to acquire OMP data either directly or with
an aggregator.
5.5 Options available to a market participant for OMP reporting
Given the above offering types, a market participant has the following options when deciding how to meet the first
phase of REMIT reporting obligations:
-
Sign a direct reporting agreement with each OMP used
Upload data from all OMPs and send it to one or more full RRM
Ask OMPs to send data to full RRMs
Use a aggregated service
Combinations
5.5.1
Direct reporting agreements with all OMPs
Under this model, the market participant signs a direct agreement with each OMP, as outlined in section 5.4.1.
However, if broker platforms are amongst the OMPs in question, an arrangement needs to be made to pass post
trade events to ACER. If the OMP offers a mechanism themselves to report such events then this can be used.
Otherwise a full RRM will need to receive such events.
Similarly, data such as beneficiary ID and others will also need to be given to the OMP if the market participants
trades as agent.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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