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Regulations
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Cancel or Reject: OATS reporting
John Prewett / Lava Trading (Citi)
7 Sep 2011 6:15PM ET Several of the recent regulatory issues refer to rejecting or canceling orders. One example of this is the about-to-become-live Market Access Rule. I am uncertain as to whether the regulations, which sometimes seem to treat the words "rejected" and "canceled" synonymously, directly infer a FIX ExecReport(ExecType=Rejected) and ExecReport(ExecType=Canceled) respectively.
With the upcoming Market Access Rule, if a user exceeds his/her credit limit, the broker/dealer can "refuse to process" the order (I won't say rejected or canceled here). According to our compliance department, this order is OATS reportable.
From what I understand, many of our customers know that a FIX ExecReport(ExecType=Rejected) means "doesn't require OATS reporting", whereas a FIX ExecReport(ExecType=Canceled) means "does require OATS reporting.
So are we now entering a new age where a FIX ExecReport(ExecType=rejected) may conditionally require OATS reporting?
Or should these specific types of "rejections" be conveyed as an ExecReport(ExecType=Canceled)?
As a sideline to this, is there a field somewhere in the ExecReport that indicates if the order is OATS reportable or not?
Thanks
JohnP
Cancel or Reject: OATS reporting
John Prewett / Lava Trading (Citi) 7 Sep 2011 6:15PM ET
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