Question:
Our understanding is that the fields in the below table would remain the same (“persist”) for the life of a UTI and will not change when there is a lifecycle event on the UTI. Is this in line with CFTC’s expectation?
| Field | Persist | Rational | CFTC Feedback |
| Platform Identifier | Yes | Under EMIR, the industry will persist the Venue of Execution value (except for compression events). We propose the same for CFTC reporting of Platform Identifier #98 (i.e. the MIC used in Platform ID #98 would persist for posttrade events, except for compression events which results in the issuance of new UTIs. Is this in line with CFTC’s expectation? | CFTC responded that if a post-trade event creates a new UTI, then this ID would not persist. Otherwise, the ID would persist for posttrade events that do not result in a new UTI. |
| Package Identifier | Yes |
The industry believes that Package Identifier #46 reported on the original new trade should persist through the life of the trade, even for post-trade events. Is this in line with CFTC’s expectation? For example, where an RCP originally reported a Package that consisted of three trades, then the RCP subsequently executes a bilaterally agreed post trade event on only one of them, is it CFTC’s expectation that the original package ID should be persisted on this trade? |
CFTC responded that if a post-trade event creates a new UTI, then this ID would not persist. Otherwise, the ID would persist for posttrade events that do not result in a new UTI. |
| Prime Brokerage Transaction Indicator | Yes | Market participants believe that #99 would remain the same for the life of a UTI; #99 would not change when there is a lifecycle event (such as an amendment) on such UTI. Is this in line with CFTC’s expectation? | CFTC responded that if a post-trade event creates a new UTI, then this ID would not persist. Otherwise, the ID would persist for posttrade events that do not result in a new UTI. |