REMIT Reporting Services and Solutions - July 2015 updated March 2016
6.4 Comparing solution types
The following chart compares the solution types and considers when each would be appropriate:
Delegation (via
OMPs or other, e.g.
to counterparty)
Upload using files to
RRM
Pros
Cons
Considerations
When best
Least amount of “work”,
especially with heavy use of
OMPs.
Can delegate off venue trades
to one or more
counterparties
Delegated responsibility
under REMIT
Complete control
In some cases a simple
solution
May be relatively cheap for
smaller volumes
Control of data
How many OMPs are
traded on
Volumes
For off venue, number of
counterparties and
whether they offer
delegated reporting
Those who trade on few OMPs, or
for small market participants who
trade with larger counterparties
offering a delegated service.
Access to data still needs to be
considered. Also consider new
answer of February 2016.
Volume
Complexity and variety
of data
For those with a small amount of
data
Volume
IT capability
Willingness to be
transparent
For larger players who have a
deep IT capability and wish to
maintain control
Where is data?
Does vendor offer a
connector and to which
destination?
Cost
For those where most data is in
one RRM and vendor offers a
solution
Direct send to ACER
(i.e. become RRM)
Full control
Access to information from
ACER
No fees
Software – ETRM
Adapter
Could be a simple solution
Outsource work of
understanding requirements
to someone else
Maintenance of adapter by
someone else
Could require many agreements
Loss of control
Post trade events for broker traded
May end up expensive
Loss of “control”
Lack of access to data for use in
investigations
Could get complex if too many trades
Will need to get files into appropriate
formats
Difficult to handle life cycle events
How to get how of OMP data
Hard to make work for orders
Possible increase in liability
Will need to pass ACER security and
financial requirements
Will need to pass ACER tests
Subject to audit
Not permitted for OMP data
Possible increase in liability
Only works if most data is in one
ETRM
Relying on someone else for solution
How to handle orders and OMP
trades
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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