Order Record Keeping Available for Testing

22nd August 2016

Article 25 of MiFIR requires trading venues to maintain records of all orders advertised through their systems. RTS 24 significantly expands this obligation to capture considerable amounts of new data relating to orders so that a trading venue can store this data for submission to their NCA when requested.

These requirements present Cboe and other trading venues and their users with a challenge: how to capture and store sensitive data in a way that provides Participants and their clients with peace of mind and doesn't damage the efficiency of the order execution process.

Cboe has consulted extensively with users, market participants and other trading venues to develop a solution that it believes can be adopted as a standard. Cboe has previously communicated about the solution; you can read more about it at the following locations:

To recap, Cboe's approach involves supplying 'short code IDs' on orders and then supplying the mapping from those short codes to their longer form National IDs or Algorithm IDs through a mapping file out of band. This mapping file is stored securely until such time as a regulator requests the relevant order records.

Cboe is pleased to announce the availability in our customer test environments of the complete record keeping system for Participant testing, 16+ months ahead of the MiFID II implementation date. It is hoped that individual Participants will benefit from the extended testing period. Feedback is appreciated and will be considered to the benefit of the overall community of Cboe market participants.

In our certification environments, Participants are able to:

  • Supply relevant identifiers and flags using either FIX or BOE.
  • Use the Cboe Secure Web API to register and otherwise manage the identifiers, using the Identifier Management API.
  • Use the Identifier Management API to view missing mappings and fill in the gaps.

Participants wishing to certify and supply relevant identifiers in production will receive further information on how to do so on request. Any data supplied prior to the mandatory supply of identifiers on 8th September, 2017 will be removed at that date.