EMIR Workshop
Segregation & Portability – Trade Reporting
Leipzig, 05th June 2014
1
Segregation and Portability
Current Status EMIR Licensing
Submitted Application
12.09.2013
First College Meeting
29.04.2014
20.12.2013
Application Complete
Formal License
at latest 15.06.2014
15.05.2014
College Voting
2
Segregation and Portability
Model Overview
ECCs segregation model offers the following accounts:
• House (optional): Contains CM proprietary positions; assets are posted by
CM and segregated by value (see above) or in a separate house collateral
pool
• Individual Segregation (ISA) and Omnibus Segregation (OSA) (optional):
Contains NCM positions (ISA) or positions of clients (OSA); assets are
segregated in separate ISA/OSA collateral pool; colateral is client collateral
with full transfer in case of CM default; Collateral transformation is possible;
shortfalls are covered by surplus in the standard collateral pool
• Simple Omnibus (SOS) (optional): Contains positions of NCM or clients that
have to be treated seperately by CM; assets are posted by CM into a
separate pool;
• General Omnibus (GOS) (mandatory): Contains positions of all NCM and
clients* that are not ISA/OSA/SOS and in case no house account has been
set up also the house positions; assets are posted by CM into the standard
collateral pool and are segregated by value between house and all client
positions
* Client positions are held on A-Position accounts
3
Segregation and Portability
Collateral/Margin Flows
House
General Omnibus
Simple Omnibus (Gross Omnibus)
Net
Omnibus
Individual
Segregation
Omnibus
(NCM ID)
NCM
CM
CM
NCM
NCM
CM
NCM
NCM
House
Accounts
P1/P2
M1/M2
Client
Accounts
A1…A7
House
Accounts
P1/P2
M1/M2
Client
Accounts
A1…A7
House
Accounts
P1/P2
M1/M2
Client
Accounts
A1…A7
Client
Accounts
A1…A7
House
Accounts
P1/P2
M1/M2
Client
Accounts
A1…A7
House
Accounts
P1/P2
M1/M2
Client
Accounts
A1…A7
Client
Accounts
A1…A7
House
Accounts
P1/P2
M1/M2
Client
Accounts
A1…A7
P1/P2
A1…A7
P1/P2
A1…A7
P1/P2
A1…A7
A1…A7
P1/P2
A1…A7
P1/P2
A1…A7
A1…A7
P1/P2
A1…A7
OSA Pool
ISA Pool
ISA Pool
Simple Omnibus Pool
House Pool
Standard Pool
TARGET2 Account of CM
 Margins are only called from TARGET2 Account of the CM into the Standard Pool; if a separate House Pool has been
set up then calls for the house account will be made separately into the house pool
 Transfer of Collateral into the Simple Omnibus and ISA/OSA Pools has to be effected immediately by the CM from the
standard pool manually or by file-upload.
 Releasing collateral from the ISA or OSA requires consent of client or omnibus representative and are returned to CM
for their clients immediately after release
 Release from other House or Standard Pool requires consent of ECC (sufficient coverage).
4
Segregation and Portability
Process for Portability
-
-
According to EMIR Article 48 ECC has committed itself in the Clearing
Conditions to trigger the procedures for a transfer of positions and assets of
ISA/OSA clients in the event of a default of the CM without requiring the
consent of the defaulting CM:
For ISA/OSA NCM and clients with a backup CM ECC will transfer positions
and assets to the backup CM immediately; for ISA/OSA clients without
backup CM ECC will set a transfer window within which they can find a new
CM
For SOS/GOS NCM ECC can transfer positions on request of the NCM to a
new CM within the transfer window; assets cannot be transferred quickly
All remaining positions are liquidated and the pool collateral used according
to the specific segregation model; remaining collateral in ISA/OSA collateral
pools is returned to the clients; collateral in SOS/GOS pool can be reclaimed
by the known clients of the CM; remainder is distributed to the CM on account
of his clients
5
Segregation and Portability
Loss Allocation
Example
Collateral in
Pool
Example 1
Loss
allocated
Coverage of
Loss
exceeding
collateral
Standard Pool
GOS/SOS
House
100
House
ISA/OSA
100
GOS/SOS
150
-50
Default Fund
a.
75
+25
GOS Clients
100
ISA /OSA
b.
c.
75
+25
ISA/OSA
d.
Example 2
House
Loss
allocated
Coverage of
Loss
exceeding
collateral
GOS/SOS
0
+50
Administrator
125
-25
House
ISA /OSA
e.
125
-25
House
f.
Liquidation is performed on the net position
over all accounts (one netting set)
The Liquidation result is allocated to position
accounts (maximum the amount that would
result when only liquidating that account).
If the allocated loss in the house position
account exceeds the allocated collateral (see
previous slide), this shortfall cannot be covered
with GOS or ISA/OSA collateral
If the allocated loss in the ISA/OSA position
account exceeds ISA/OSA collateral + allocated
collateral from the standard pool, this shortfall
cannot be covered with other GOS or ISA/OSA
collateral.
Any loss of a non ISA/OSA position account can
be covered with GOS or house collateral.
Collateral allocated to house position accounts
can be used to cover loss of any other position
account
6
Segregation and Portability
Major Operational Impact
•
•
•
•
•
•
•
Only NCM can become ISA (i.e. a client must become NCM first); Clearing
Broker Model can be used if NCM does/shall not have access to markets
OSA are technically set up identical to ISA but contain several clients. Identity
of those clients has to be disclosed to ECC for legal purposes however
positions and collateral are not segregated at ECC. EMIR segregation
requirements1 have to be implemented by Clearing Member
For ISA/OSA new collateral pools have to be set up; new CBF accounts or
sub-accounts if securities are used as collateral.
Collateral received from clients has to be passed on to ECC if ISA/OSA
segregation is selected.
Additional legal documentation required for ISA/OSA
ECCs rulebook (close out provisions) will be amended to contain EMIR
compliant rules for segregation of collateral in the event of a default of a
Clearing Member
Individual close out provisions between Clearing Member and ECC can remain
but have to be approved by ECC; use of ECC standard is recommended
1 EMIR
Article 39 (4), (5)
7
Segregation and Portability
Cash Collateral Processing
•
•
•
•
Book only transfers of cash collateral (without actual cash movements) between
segregated collateral pools underneath a Clearing Member are possible to avoid double
funding issues
ECC performs book only transfers on behalf of its Clearing Members
Book only transfers can be performed from GOS to segregated pools but not between
segregated pools
CM has to advise ECC via a .csv file of the requested book only transfers until 11 am CET
Deposit /Withdrawal balanceOnly
•
•
•
mandatory
mandatory
either D or W
always Y
CLGMbr
mandatory
PoolID
mandatory
CURR
mandatory
Amount
mandatory
CSD
PledgeAcc MainAct
ISIN
./.
./.
./.
./.
always
empty
always
empty
always
empty
always
empty
Text
optional
One file per day, only EUR is supported. The file has to be sent via email to ECC
(clearing@ecc.de) and will be replied to individually upon processing
Incorrect/ incomplete files will be rejected by ECC. The Clearing Member will be informed
accordingly and can modify and resend the file for processing to ECC
In case no sufficient margin surplus is available to cover requested book only transfers
within a file, ECC will reject entire transfer; partial transfers are not possible
8
Segregation and Portability
Bond Collateral Process
•
Basic bond collateral process remains unchanged: CM requests posting/withdrawal via
Eurex @X-tract Clearing GUI or existing form. The request must contain which
collateral pool should be used (pool ID).
•
Intraday withdrawals of bonds is only possible for excess in GOS / house account pool
(i.e. not below margin requirement of that pool)
•
CM initiates bond transfer to/from the CBF Pledge Account that is linked to the
collateral pool; assignment in Eurex will be automatic
•
CM can see the deposits in Eurex@X-tract Clearing GUI and on Eurex Clearing reports
near to real time
•
Only Clearstream Banking Frankfurt (incl. 6 series creation accounts) is in scope for
first phase
•
Deadline for withdrawal and posting is 17:00 CET
9
Segregation and Portability
Legal - General Changes
 GOS
• No change of existing NCM-Agreements necessary, CM clients without NCM status
will be automatically covered
• Changes in ECCs Clearing Conditions regarding account keeping and close out will
apply
 Individual Segregation
• Existing NCM-Agreements can remain in place. Additionally the following
documentation is needed:

Trilateral Collateral Agreement as Appendix to NCM-Agreement (existing Collateral
Agreement has mostly been integrated into the Clearing Conditions); and

Power of Authority for ECC regarding the Transfer of Collateral in urgent cases (not
mandatory but strongly recommended for collateral transfer)
 Omnibus Segregation
• No NCM-Agreements in place as Omnibus Segregation is only for non-NCM clients

Omnibus Representative Agreement: four party agreement between the Omnibus
Representative, the Clearing Member, the Clients of the Clearing Members and ECC.
10
Segregation and Portability
ISA/OSA Close Out Netting Arrangements
(I) Individual documentation based on standard market documentation:
•
•
•
German Master Agreement for Financial Services Transactions (Deutscher Rahmenvertrag für
Finanztermingeschäfte)
Clearing Master Agreement (Clearing-Rahmenvereinbarung) of the German Banking
Association (BdB) may be used to determine relationship between CM and NCM/Client in the
future. In relation to ECC this Agreement might have to be used together with a special ECCAnnex.
ECC will rely on the legal opinions commissioned by industry association (German
Banking Association).
(II) Individually agreed client documentation
•
•
•
Individual close out netting provisions between CM and ECC can remain in place but
have to be in compliance with the regulatory EMIR framework for segregation to ensure
that an NCM/OSA is fully protected in a default situation of a CM.
ECC has to approve the relevant agreements
Use of ECC standard is recommended
11
Contact
Segregation Model:
Marcus Knappe
Director Risk Controlling & Bank Compliance
EMIR Risk Officer
Phone: +49 341 24680-530
E-mail: marcus.knappe@ecc.de
Operations:
Sebastian Weinreich
Senior Expert Clearing & Settlement
Phone: +49 341 24680-505
E-mail: sebastian.weinreich@ecc.de
Legal:
Dr. Anja Greenwood
Senior Expert Legal Affairs
Phone: +49 341 2156-252
E-mail: anja.greenwood@eex.com
12
EMIR Workshop
Trade Reporting according to EMIR Article 9
Leipzig, 05th June 2014
EMIR Reporting Requirements & ECC‘s Approach
Reporting Requirement of EMIR Article 9
EMIR Article 9
•
Counterparties and CCPs shall ensure that the details of any derivative
contract they have concluded and of any modification or termination of the
contract are reported to a trade repository
•
The reporting obligation shall apply to derivative contracts which:
(a) were entered into before 16 August 2012 and remain outstanding
on that date;
(b) are entered into on or after 16 August 2012.
•
A counterparty or a CCP which is subject to the reporting obligation may
delegate the reporting of the details of the derivative contract.
•
Counterparties and CCPs shall ensure that the details of their derivative
contracts are reported without duplication.
14
EMIR Reporting Requirements & ECC‘s Approach
Reporting Structure
Principles of ECC Trade Reporting
•
•
Open offer model implies that cleared transactions immediately exist upon
matching.
Due to the principal-to-principal model, the Clearing Member (CM)
concludes a transaction with ECC as well as, in case of Non-Clearing
Member (NCM) or client business, a back-to-back transaction with its NCM
or client. Thus, up to four trades/positions are reportable for any
transaction.
• Reporting has to match between the respective counterparties
• ECC currently understands, that only Counterparty IDs, UTI1 and TRN2 as
well as Common Data Fields are reconciled.
1
Unique Trade Identifier, 2 Transaction Reference Number
15
EMIR Reporting Requirements & ECC‘s Approach
Status of ECC Partner Exchanges
ETD and OTC Reporting
•
•
The regulatory status of a market determines the reporting obligation.
All transactions on markets classified as ETD (Exchange Traded
Derivatives) or OTC must be reported under EMIR Article 9.
Market
Exchange Trades
Registered Trades
EEX (all markets), CEGH, PXE
ETD
Powernext
OTC
HuPX
No derivatives, not included in trade
reporting
NXE
To be decided
16
Technical Details & Reporting Codes
Trades and Positions
Trade Reporting
•
•
•
•
Trades are reported in their end-of-day status
Lifecycle events (splits, give-ups, take-ups) are not reported
All trades are netted end of day
Netting is reported as a modification of action type compression
Position Reporting
•
•
•
•
•
Positions are reported as separate transactions with separate UTI
The Position UTI remains unchanged over the lifecycle of the position
Lifecycle events are reported as a position modification
Any reported position originates from a compression exercise
Position level reporting is required to allow positions level life cycle events
like position transfer to be correctly reflected in the trade reporting
17
Technical Details & Reporting Codes
Exposure Reporting
Exposure Reporting
•
•
•
•
•
The reporting start for exposures (ESMA Fields 17-26) has been
postponed by 180 days by ESMA.
Thus, ECC will report exposures from 12th August 2014.
Exposures have to be reported by Financial Counterparties and NonFinancial Counterparties above the Clearing Threshold (NFC+)
Exposures will be reported for positions only (not for transactions)
ECC expects further clarification from ESMA concerning exposure fields
18
Technical Details & Reporting Codes
Backloading
Backloading
Derivative contracts, which
•
were outstanding on or after 16th August 2012 and are still outstanding on
12th February 2014 have to be backloaded within 90 days.
•
•
ECC has not used the 90 day grace period and backloaded all outstanding
derivatives contracts on 12th February 2014
were outstanding on or after 16th August 2012 and are not outstanding on
or after the 12th February 2014 have to be backloaded within 3 years
•
ECC does currently not plan to backload these derivative contracts following
the ESMA Q&As TR Answer 4(a)
19
EMIR Reporting Requirements & ECC‘s Approach
Delegation Overview
Possible Delegation Setup
• EMIR allows for delegation to one’s direct counterparty or a third party
Reporting Entity
Clearing Member
Non-Clearing Member
Account/
Leg to report
Proprietary
Accounts
Agency
Accounts
NCM
Accounts
Full
Delegation
Full
Delegation
Full
Delegation
n/a
n/a
CM – Client
n/a
No
Delegation
Full
Delegation
Full/Partial
Delegation
Full/Partial
Delegation
Client –
Indirect Client
n/a
n/a
n/a
n/a
No
Delegation
CM – CCP
Proprietary
Accounts
Agency
Accounts
20
Technical Details & Reporting Codes
Reporting Codes at ECC
Reporting Codes
•
In case of proprietary reporting by CMs or NCMs, ECC expects its UTI,
Position UTI and TRN to be matched.
•
Source for UTI, Position UTI and TRN construction
•
End-of-day “CB010 Position Detail” Report
•
End-of-day “TC810 Daily Trade Confirmation” Report
•
Convention for UTI, Position UTI and TRN construction have been published
in ECC’s Clearing Circular 01/2014.
•
All end-of-day reports are available via the Common Report Engine.
•
Alternatively, fields may be accessed via FIXML interface of the Eurex
Clearing System.
21
Technical Details & Reporting Codes
Unique Trade Identifier
•
ESMA has not yet endorsed an official Unique Trade Identifier framework
•
Each pair of reports or single report should have the same UTI
•
ECC expects members with a proprietary reporting solution to match ECC’s UTI
•
The European Association of Clearing Houses Working Group failed to establish a
common UTI framework but agreed UTI should start with CCP MIC Code ensuring
that no equivalent Unique Swap Identifier exists.
•
Example Unique Trade Identifier:
000XECC00
E
20131029
F1BM
000123ABC
00001
A1B2C3D4E
B
C
ECC MIC
CODE
UTI Type
Indicator
Trade Date
Product
ID
Transaction
ID Number
Transaction ID
Suffix Number
Order ID
Buy
Code
Clearing
22 Leg
Indicator
TC810
CB010
CB010
22
Technical Details & Reporting Codes
Transaction Reference Number
•
TRN was originally introduced to link MiFID and EMIR reporting
•
TRN should be the same among groups of reports which relate to the same
execution and have its origin in a centralized infrastructure
•
ECC will use the Clearing Code generated at CCP level
•
Parties are expected to transmit the TRN to their Counterparties
•
Example Transaction Reference Number:
Trade Date
Product ID
Transaction ID Number
20131029
F1BM
000123ABC
CB010
23
Technical Details & Reporting Codes
Position UTI / Position TRN
•
ESMA has not yet endorsed an official Unique Trade Identifier framework
•
Each pair of reports or single report should have the same UTI
•
ECC expects members with a proprietary reporting solution to match ECC’s UTI
•
Position UTI will remain unchanged over the lifecycle of the position
•
Position TRN will not be used
•
Example Position Trade Identifier:
000XEC
C00
P
ABCEX
P100000000
0000000000
O1BM
P
1410
0
049000
T
ECC MIC
CODE
UTI Type
Indicator
Member
ID
Account
Type
Product
ID
Contract
Class Code
Contract
Expiration
Version
Number
Strike
Price
Clearing Leg
Indicator
CB010
24
ECC EMIR Trade Reporting Service
Overview
Trade Repository
•
Regis-TR
Prerequisites
•
•
•
•
Full Reporting Participant Membership with Regis-TR
EMIR Trade Reporting Service Form
EMIR Trade Reporting General Terms and Conditions
NCMs only: CM has delegated reporting to ECC
Delegation Scope
•
•
•
Trade Reporting
Position Reporting
Backloading
Liability
•
Delegating Party
Fees
•
•
Fixed Monthly Fee: EUR 200.00
Payable on an annual basis on 15 January of the year following
service provision
25
Contact
ECC Clearing Member / Non-Clearing Member
Monika Schrod
ECC Risk Controlling & Bank Compliance
Phone: +49 341 24680-531
E-mail: monika.schrod@ecc.de
26
Contact
Thank you for your attention!
27
EMIR Workshop
Trade Reporting according to EMIR Article 9
Backup Slides
28
Technical Details & Reporting Codes
Unique Trade Identifier Details
UTI Component
ECC MIC Code
Length
10
Format
Report
Field Mapping
000XECC000
UTI Type
Indicator
1
E = ECC ETD Trades
W = Wholesale Trades
CB010
If trdTyp = “ ” Then “E”
If trdTyp in
(“A”,”B”,”E”,”F”,”N”,”O”,”P”,”V”,“W”)
Then “W”
Trade Date
8
YYYYMMDD
CB010
origTrnDat
CB010
prodId
CB010
trnIdNo
CB010
trnIdSfxNo
TC810
ordrNo
(If there is no OrderID, the field will be
filled with nine “0” characters.)
CB010
buyCod
Product ID
4
Transaction ID
Number
9
Transaction ID
Suffix Number
5
Order ID
9
Buy Code
1
Clearing Leg
Indicator
1
4 Alphanumeric Characters
If Length(prodId)<4, fill with
trailing spaces.
Alphanumeric
(“000”&trnIdNo)
Numeric
If Length(trnIdSfxNo)<5, fill
with leading 0s.
Alphanumeric, filled with nine
“0” characters if no Order ID is
given
Alphanumeric
( B=Buy, S=Sell)
C = CCP / CM Trade
T = CM / NCM Trade
29
Technical Details & Reporting Codes
Transaction Reference Number Details
TRN
Component
Trade Date
Length
Format
CB010 Field Mapping
8
YYYYMMDD
origTrnDat
Product ID
4
4 Alphanumeric
Characters
If Length(prodId)<4,
fill with trailing
spaces.
prodId
Transaction ID
Number
9
Alphanumeric
(“000”&trnIdNo)
trnIdNo
30
Technical Details & Reporting Codes
Position UTI / Position TRN Details
UTI Component
Length
Format
CB010 Field Mapping
ECC MIC Code
10
000XECC000
UTI Type Indicator
1
P =Position
Member ID
5
5 Alphabetic Characters
membExchIdCod
Account Type
20
2 Alphanumeric Characters
acctTypGrp
4
4 Alphanumeric Characters
If Length(prodId)<4, fill with
trailing spaces.
prodId
Product ID
Contract Class Code
1
F = Future
C = Call
P = Put
Contract Expiration
4
YYMM
Version Number
1
“0”
Strike Price
6
Clearing Leg
Indicator
0/1
For options
6 digits, filled up with leading “0”
if less than 6 digits
For futures
“000000”
“” = CCP / CM Position
T = CM / NCM Position
If cntrClasCod = “ ”
Then “F” Else
cntrClasCod
Right(cntrExpYrDat;2) =YY
cntrExpMthDat = MM
n.a. for ECC futures/options and not
contained in CB010.
cntrExerPrc
31
Technical Details & Reporting Codes
Unique Product Identifier and Product Identification
•
•
ESMA has not yet endorsed an official Unique Product Identifier framework and
ECC expects further guidance on UPI taxonomy “U”
CFI Codes are currently not available to facilitate the utilization of UPI taxonomy “I“
Common Data Field
Futures
Options
Taxonomy Used
E
E
Product ID 1
CO = Commodity
CO = Commodity
Product ID 2
FU = Futures
OP = Option
Option Type
Maturity Date
P = Put / C = Call
YYYY-MM-DD
Strike Price
Underlying
•
YYYY-MM-DD
Strike Price
ISIN of Future
ISIN of Underlying Future
Additional product information is available through the energy-related Common
Data Fields
32
Technical Details & Reporting Codes
Specific Common Data Fields (1/2)
Reporting Field
Compression
Execution Timestamp
Maturity Date
Intragroup
Field Interpretation
Trades: “N”
Positions: “Y”
UTC Time Format (YYYY-MM-DDTHH:MM:SS±HH:MM),
Clearing Timestamp = Matching Timestamp
Expiry Date for Contract
For futures that expire before the delivery period the Maturity Date and
Settlement Date will be reported as the Last Delivery Date.
“Y” = Yes / “N”=No
Commodity Base
“EN” = Energy for Electricity, Gas and Coal
“EV” = Environmental for Emissions and GoOs
Commodity Details
“NG” = Natural Gas
“CO” = Coal
“EL” = Electricity
“EM” = Emissions and GoOs
Delivery Point or Zone
EIC of TSO Zone or EIC of Virtual Trading Point
33
Technical Details & Reporting Codes
Specific Common Data Fields (2/2)
Reporting Field
Field Interpretation
Interconnection Point
““
Load Type
“Base Load”, “Peak Load”, “Off-Peak”, “Other”
Delivery Start Date and
Time
UTC Time Format (YYYY-MM-DDTHH:MM:SS±HH:MM)
Delivery Start of Contract
Delivery End and Time
UTC Time Format (YYYY-MM-DDTHH:MM:SS±HH:MM)
Delivery End of Contract
Contract Capacity
= Price Multiplier
Quantity Unit
= Contract Capacity divided by the Number of Delivery Days
Price Time Interval
Quantities
““
34
Technical Details & Reporting Codes
Reporting Example (1/2)
t1
Trade
ABCEX (CM: XYZEX) sells 5 lots of F1BY 01/2015 (No Position F1BY 01/2015 exists)
t2
t2
Reporting
Type
Trade
Reporting
Identifier
Further Details
CCP/CM Trade
New Trade
UTI1 / TRN1
CM/NCM Trade
New Trade
UTI2 / TRN1
CCP/CM Trade
Modification
UTI1 / TRN1
Action Type = Compression
CM/NCM Trade
Modification
UTI2 / TRN1
Action Type = Compression
CCP/CM Position
New
Position UTI 1
Compression Field = Yes
CM/NCM Position
New
Position UTI 2
Compression Field = Yes
Identifier
Further Details
ABCEX (CM: XYZEX) buys 2 lots of F1BY 01/2015
Type
t3
Message
Message
CCP/CM Trade
New Trade
UTI3 / TRN2
CM/NCM Trade
New Trade
UTI4 / TRN2
CCP/CM Trade
Modification
UTI3 / TRN2
Action Type = Compression
CM/NCM Trade
Modification
UTI4 / TRN2
Action Type = Compression
CCP/CM Position
Modification
Position UTI 1
Compression Field = Yes
Quantity / Valuation / Collateral
CM/NCM Position
Modification
Position UTI 2
Compression Field = Yes
Quantity / Valuation / Collateral
35
Technical Details & Reporting Codes
Reporting Example (2/2)
t3
Trade
ABCEX (CM: XYZEX) does not trade
t4
tEXP
Reporting
Type
Expiry
Reporting
Identifier
Further Details
CCP/CM Position
Modification
Position UTI 1
Compression Field = Yes
Valuation / Collateral
CM/NCM Position
Modification
Position UTI 2
Compression Field = Yes
Valuation / Collateral
Expiry of F1BY 01/2015 (ABCEX already holds a Position in F1BM 03/2015 and F1BQ 04/2015
Type
tEXP+1
Message
Message
Identifier
Further Details
CCP/CM Position
Cancellation
Position UTI 1
Automatic Cancellation
CCP/CM Position
New (F1BM 01/15)
Position UTI 3
Compression Field = Yes
CCP/CM Position
New (F1BM 02/15)
Position UTI 4
Compression Field = Yes
Modification (F1BM 03/15)
Position UTI 5
Compression Field = Yes
Quantity / Valuation / Collateral
Modification (F1BQ 04/15)
Position UTI 6
Compression Field = Yes
Quantity / Valuation / Collateral
CCP/CM Position
New (F1BQ 07/15)
Position UTI 7
Compression Field = Yes
CCP/CM Position
New (F1BQ 10/15)
Position UTI 8
Compression Field = Yes
CM/NCM Positions
Cancellation
New / Modification
Position UTI 2
Position UTI 9 - 14
Compression Field = Yes
CCP/CM Position
CCP/CM Position
36