TRUP 3

As advised in Regulatory Roundup 28, the FSA is in the process of reviewing the Transaction Reporting User Pack (TRUP), which is a useful source of reference for those firms with transaction reporting obligations under SUP 17.

The current Transaction Reporting User Pack (TRUP) (version 2), dates back to 21 September 2009.

The FSA has released a draft update which will include guidance published elsewhere and issued since the publication of version 2.

Portfolio managers relying on the exemption in SUP 17.2.2 will see that section 9.6.2 incorporates previous guidance given on how such a firm can satisfy the ‘reasonable grounds’ requirement of SUP 17.2.2(2). The portfolio manager is not required to ensure that reports are being submitted accurately as this is an existing obligation of the broker. This reflects the advice given in Market Watch 35 in July of last year. Section 9.6.3 reminds portfolio managers when they cannot rely on this exemption and includes in sub-paragraph e) enhanced guidance for when EEA brokers agree to transaction report on behalf of the firm rather than in their own capacity.

Those firms that do transaction report are provided with a link in 10.1 to enable them to request a sample of transaction reports they have submitted.

Section 3.2 concerning ‘Reportable instruments’ has been amended to advise that transactions in commodities, interest rate and foreign exchange are not reportable unless those derivatives are securitised and admitted to trading on a regulated market or on a prescribed market.

It is noted from the footnote in section 7 that the FSA has put on hold the intention for reporting firms to require a BIC – see e.g. Regulatory Roundup 28.

Comments from firms are invited by 24 November.

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