FIX Trading Community, the non-profit industry standards organisation that promotes adoption of the Financial Information eXchange (FIX) protocol, has announced updates to the FIX protocol addressing MiFID II and MiFIR requirements.
The organisation will also advise its members to review and adopt the updates as soon as possible so development work can begin, according to Irina Sonich-Bright, co-chair of the FIX Trading Community MiFID II Transparency Working Group. Sonich-Bright also is director of global markets electronic product and head of business development for AES Europe at Credit Suisse.
The updates include extension packs addressing clock synchronisation, post-trade flagging obligations, and several critical data requirements concerning transparency, order data and recordkeeping.
“The majority of straightforward scenarios have been addressed already,” says Sonich-Bright. “Gaps typically come from members who have begun implementation and realized that certain situations aren’t addressed. This is typical of MiFID II, because it’s so complex, every time you strip away one layer, you find other details you did not see or consider before.”
For post-trade flagging obligations, one of FIX Trading Community’s extension packs addresses trade reporting. MiFID II requires all counterparties in a trade to report it, which sets up an issue for how those parties will know where the trade has been reported, and in what capacity it was executed. FIX Trading Community’s updates address this issue, Sonich-Bright explains.
The industry organisation’s updates address transparency and record keeping issues by setting up a decision tree based on ESMA RTS guidelines that articulate MiFID II and MiFIR requirements. The decision tree can be used to implement trade reporting tools.