ESMA Q&A 1703 — Q&A — Transaction reporting [Answer Published]

Transaction reporting

Question

Could there be circumstances where the buyer and seller in a transaction report made under Article 26 of MiFIR are the same?

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Answer

[ESMA 70-1861941480-56 MiFIR data reporting Q&A, Q&A 24.3]

Yes, where a firm or investment firm, Firm A, instructs an investment firm, Firm B, to make a simultaneous buy and sell for its clients but Firm A has not complied with the conditions for transmission under article 4 of Commission Delegated Regulation (EU) 2017/590. If Firm B executes these transactions outside a trading venue then it should report the ISO 17442 LEI of Firm A in the buyer and seller fields in its transaction reports.

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Source: ESMA original document