How to report execution timestamp on allocations

ISDA Question

Example 11 “Allocations” of the Tech Specs (pasted below) illustrate that the time of the creation of the allocation swap (e.g. the swaps the are the result of
allocations) is both the Event Timestamp and Execution Timestamp.

We believe industry practice has historically been:
• the Execution Timestamp from the block execution/swap is brought forward to report as Event Timestamp on the allocation swap;
• report the time of allocation in the Event Timestamp.

However, Example 11 shows that the Execution Timestamp shouldn’t be brought forward from the block execution/swap.

Q: Are firms are planning to report in the Rewrite per Example 11, and no longer bring forward the Execution Timestamp from the block execution/swap to report as Event Timestamp on the swaps the are the result of allocation?

Screen Shot 2022-11-03 at 3.38.30 PM

Working Group Response:

10/27/22 WG call: The WG agreed that since Example 11 of the Tech Specs shows that the Execution Timestamp from the block execution is not carried forward to report as the Event Timestamp of the allocation swap, it would be challenging to do any differently. Firms indicated they plan to be consistent with the Example 11 approach of reporting the time of the creation of the allocations in both the Event Timestamp and Execution Timestamp fields, as shown in rows 3 and 4.