FCA Launch Consultation on TRUP 3.1
The FCA has published ‘guidance consultation’ on a revision to the (MiFID) Transaction Reporting User Pack version 3 with a view to the publication of a TRUP version 3.1.
The consultation document shows the marked up changes to the existing TRUP and whilst this appears at first glance to show substantial changes, actually much of it simply results from the updating of references and the correction of minor changes. However, the FCA set out a number of ‘clarifications’ to existing guidance including:
- transaction reports a firm sends for its transactions must accurately reflect the change in position for the firm and its client(s) resulting from the transactions
- that a firm hitting its own order on a trading venue should transaction report the resultant transaction
- how the unit price should be reported for different instruments
- how to report the venue for a transaction
- transaction reporting arrangements within firms – making it clearer what steps a firm should take to comply with its SYSC obligations
The FCA ask for responses to the consultation by Friday 4 July.