There is very little of note in ESMA’s update to its MiFID II guidelines on transaction reporting announced on Tuesday 8 August. Most of the changes are to reflect the current references for regulations and a few corrections of CFI codes used in the examples.
Of note are the following:
Execution within the firm field
Where an investment firm is instructed on where to execute a trade, the client is instructing the execution. The original text stated you populated the “Execution within the firm field” with “Client”. This has now been changed to “NORE” which we think means “No reference”.
(See 5.12: Block 5: Execution within the firm field)
Reporting as DEA provider
A more significant update, is in respect of DEA trading where you are the DEA provider. Previously, the guidelines indicated that the execution within the firm field should be populated with an Algo identifier for the order management system that routed the order to the trading venue. This has now been changed to “NORE”.
(See 5.25: Direct Electronic Access (DEA)