Cboe has issued a reminder to Brexit program participants, as they must fulfill the transaction reporting requirement that arises under Cboe’s Rules when conducting cross border trading.

Cross border trading is defined as trading activity conducted by a Participant that is not subject to a direct transaction reporting obligation in the jurisdiction in which the relevant Cboe venue is located. To ensure continuity of access on completion of the UK’s transition period, impacted Participants are required to certify for a transaction reporting solution by Friday, October 30, 2020.

Existing non UK or EEA regulated firms will need to continue to transaction report on the relevant Cboe venue, as appropriate.

On completion of the UK’s transition period, the following Participants will additionally be in scope:

• UK regulated firms who plan on conducting trading activity on the Cboe NL venue (DXE)
• EEA regulated firms who plan on conducting trading activity on the Cboe UK venue (BXE/CXE)

Participants should use the Cboe Regulatory Transaction Reporting Gateway (RTRG) service to submit transaction reports to Cboe who will then forward them onto the relevant regulator. The specification for this service can be found here and Participants who need to begin using this service should contact the Trade Desk to begin onboarding and certification.

Participants are now able to use service providers such as Unavista who have technically certified for RTRG though an individual Participant certification will still be required to ensure correct transaction report data is sent to Cboe.

The introduction of Participant short code information on orders through MIFID II means that (if used correctly) Cboe have the information required to generate transaction reports for clients conducting trading activity in a Deal (Principal) capacity. Participants opting in to this offering will have transactions for their order book executions generated and sent to the required regulator by Cboe.

Participants can opt in to this offering at a bank code (clearing firm) level.

To guarantee readiness, participants will have to ensure they have successfully certified and onboarded for one of the above transaction reporting solutions by no later than October 30, 2020. Any impacted Participants who have not certified for a transaction reporting solution by this date will risk having access to the out of jurisdiction Cboe venue (depending on entity registration) and will be suspended effective January 4, 2021.

More details can be found on Cboe’s Brexit Microsite.