Reports EU Regulations REMIT Reporting Services & Solution | Page 51

REMIT Reporting Services and Solutions - July 2015 updated March 2016 7 Planning for compliance as a market participant – tasks to carry out In order to plan a REMIT solution it is recommended that the following steps be carried out, at a minimum. We will examine the steps at a high level only. Each market participant will have a different situation and therefore the appropriate plan will differ from case to case. Each section here is brief, since they will rely on the tools provided in previous sections. [Note that sections 7.1 to 7.5 were not updated in later versions of the document.]       Registration Product list Locate data Overall solution shape Phase 1 solution Stay in touch and implement 7.1 Registration It is recommended that registration be commenced as soon as possible. Under some NRAs, the deadline for registration commencement was 17th June and others will require registration shortly. While registration does not have to be completed before reporting starts, there is little downside to entering the information required as soon as it is available. 7.2 Product List It is important to create a list of all eligible products traded, including those which must be reported as a matter of course and those which needs to be reported “on demand”. The list will form the basis of decisions as to solution shapes, and allow a market participant to work out where the data actually is. Once the list is created, it is necessary to determine under which format it will be reported under REMIT, since the data will need to be located. If the trade is “on venue” it will be in the first format. Other trades may be in one of the other 3 formats as well. Part of this step involves listing which OMPs the products are traded on, and whether they are exchanges or broker platforms. This will be a major determinant in establishing the solution shape. 7.3 Locate data Once the product list has been created, it is important to understand where the data for each field required is located. For on venue trades, the location may well be the venue itself (and this is likely to be the case for orders). Even if this is the case, it is worth noting whether a copy also reside on site. Each field in the TRUM needs to be mapped, even if at a basic level, in order to ensure that there is a route for the data to reach ACER. 7.4 Overall solution shape This stage is possibly the most important one of preparation, working out the “solution shape”, i.e. whether to use OMP reporting, delegation, software, a service or a combination, as has been examined above. It is recommended that vendors, including RRMs and OMPs only be selected once the shape has been established. Having said this, it is worth looking at what is available before establishing the shape, although this must be with reference to the specific needs and satiation of the market participant. As such therefore this is very much an iterative process. 7.5 Phase 1 solution Once the overall desired shape is known, it is vital to work out how the requirements of phase 1 will be met, without delay. The shape chosen will be partly determined by the overall shape, and partly by the other factors examined in Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC 50