EMIR Refit | Navigating the Details

As preparation has started for EMIR Refit, many regulatory reporting teams are cross-functional and may be involved in implementation of various regimes including MiFIR and EMIR. Whilst familiarity of multiple reporting regimes may be of benefit in aiding understanding of the requirements, there are some distinct differences between seemingly similar fields and the expectations of the required data. Therefore, it is important to be aware of the differences when navigating the details.

Reporting Tracking Number is not a TVTIC

ESMA is careful to point out that the Report Tracking Number (RTN) is not a one-to-one link with a TVTIC (Trading Venue Transaction Identification Code). TVTIC’s are transaction-level identifiers and are disseminated to both counterparties – buyer and seller – by a trading venue. RTNs are execution-level identifiers used to identify reports relating to the same execution. The RTNs are provided by investment firms, clearing members or CCPs.

There are still some outstanding questions regarding the generation and dissemination of the RTNs which we hope are clarified by the regulators in the upcoming months. In the meantime, it is important not to draw an association between TVTIC’s function and the function of RTNs in reporting.