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Transaction ReportingUSER’S GUIDE TO RTRS DEALER DATA QUALITY – DETAIL
Version 1.02 December 2006
Two products are available from the MSRB to measure dealer performance in reporting transactions as required by Rule G-14. The products are:
[The Summary Report was previously called the “Compliance Data Report” or “G-12(f)/G-14 Compliance Data from RTRS”] This is the user documentation for RTRS Dealer Data Quality - Detail. The user documentation for the Summary Report is at http://www.msrb.org./dfs1/revisedusersguide.htm#RealtimeStatsReport.
Purposes The RTRS Dealer Data Quality – Detail (“Detail Report”) has two purposes:
How to Obtain the Report The Detail Report is available to both dealers and enforcement agencies. Request it as you request other RTRS reports. (Dealers obtain the Detail Report in the “Reports” section of RTRS Web.)[1] Period Covered Both the Detail and the Summary Report have information about trades reported by one dealer during one month (termed the “report month”). A trade is counted in the reports if the original submission date was within the report month. The reports describe the status of the trade as of the 15th day of the following month. The period from the first day of the report month to the 15th day of the next month is termed the “processing window.” For example, when the report month is April, the processing window is April 1 through May 15. A trade is counted if it was first reported to RTRS during April and the status shown reflects all changes made through May 15. For example, a trade reported on April 20 and cancelled on May 5 is counted on the April reports as cancelled.[2] The reports are “static” in the sense that they do not reflect any changes made to the trade data after the 15th of the following month. Identification of Trades On the Detail Report, certain fields are shown to identify trade submissions. Other trade detail fields, not shown on the Detail Report (e.g., capacity as agent or principal), are available to dealers on RTRS Web screens and to enforcement agencies on their RTRS Surveillance Database screens/reports. The identifying attributes shown on the Detail Report are: Trade type (inter-dealer or customer) Submit side (buyer or seller) CUSIP number Par Price Yield Clearing ID Executing broker symbol (EBS) Dealer’s control number (“XREF”) Trade date Trade time Report date (date of first submission within processing window) Report time (time of first submission within processing window) The price and yield are shown as reported by the dealer. The “price” field for inter-dealer trades that are reported on a final money basis is zero because these trades are reported to RTRS with dollar price of 0 (instead, they are reported with final money, par and accrued interest). Trades that are reported without yield are shown with zero in the “yield” field. If the price, yield, etc. were modified during the processing window, the report shows the modified attributes. Spreadsheet Column Headings The Detail Report is provided in the form of an Excel spreadsheet. Each column heading includes an Excel “comment” that documents its meaning. The comment appears when the cursor is positioned over the column heading. If a comment is too large to be viewed when the cursor is positioned on the heading, right-click the heading and select “Show/Hide Comments,” or, to see all comments, select “View/Comments” on the menu bar (top of screen). Relationship between the Summary and Detail Reports As noted, the Detail Report identifies trades counted in each Summary Report category. A column on the Detail Report corresponds to each category on the Summary Report, except as noted in the table below. The Detail Report indicates that a trade is in one or more of these categories by displaying an “X” in the appropriate column on the same line as the trade’s identifying attributes. For example, if a trade was reported late and then amended, there will be an “X” under “Late” and another “X” under “Amended.” At the bottom of the column, the number of “X”s is counted. The count of “X”s in a column is the same as the corresponding number in the Summary Report category. For example, if the Summary Report shows ten late customer trades during the processing window that have not been cancelled and which are satisfactory or questionable, then there will be ten trades on the Detail Report with an “X” under “Customer: Late.” Attachment A is a sample Summary Report with letters in each cell showing which Detail Report column corresponds to the cell. Attachment B is an example of a Detail Report with letters over the corresponding columns. The following table keys the columns to the cells.
Trades Shown on the Detail Report The Detail Report shows a submission if:
Order of the Trades The trades are ordered by trade date and time. The user may use Excel’s capabilities to sort the rows as desired – by CUSIP number, by late/not late, etc. Treatment of Satisfactory and Unsatisfactory Trades The Detail Report, like the Summary Report, distinguishes “satisfactory” and “questionable” trades, on the one hand, from “unsatisfactory,” “cancelled” or “unmatched” trades, on the other. If a trade is satisfactory or questionable, its details are shown, such as whether the trade was late or amended, presence of an invalid time of trade, and special conditions reported by the dealer. If a trade is unsatisfactory, cancelled or unmatched at the end of the processing window, the Detail Report identifies the trade but the detailed attributes (late, amended, special conditions, etc.) are not shown. The terms in quotes above are defined here. A trade report is “unsatisfactory” if it has an “unsatisfactory” error as of the end of the processing window. (“Unsatisfactory” errors are those with error codes beginning with “U”.)[3] A trade report that is not unsatisfactory is either questionable or satisfactory. A trade report is “questionable” if it has a “questionable” error at the end of the reporting window, or if it was originally submitted late. A trade report is “satisfactory” if it has no questionable errors and was not submitted late. If a dealer modifies an unsatisfactory report to make it “satisfactory” or “questionable” by the end of the reporting window, it is shown in the Detail and Summary Reports as satisfactory or questionable. An inter-dealer submission is “unmatched” if: (a) by the end of the processing window RTTM has not matched it with the contra-party’s submission; or (b) the trade has been reversed by the end of the processing window; or (c) although the submission was compared by RTTM, the destination of the contra-party’s submission did not include RTRS. Case (c) indicates that the contra-party treated the submission as other than an inter-dealer transaction reportable under Rule G-14. In this case RTRS treats both sides as “unmatched.”[4] An inter-dealer or customer trade report may be “cancelled” by the dealer. An inter-dealer trade report may also be cancelled by RTTM if it has not been matched with the contra-party’s submission by the RTTM deadline for purging.[5] Treatment of trades that are satisfactory or questionable, matched, and not cancelled: The Detail Report displays the following details about trades that are satisfactory or questionable, that are not cancelled and (if they are inter-dealer trades) that are matched with the contra-party submission: Late: A trade is shown as late if it was submitted after the reporting deadline. See Attachment C for further details. Syndicate buy/locked-in contra: A trade is shown in this category if the dealer is the buyer in a syndicate takedown transaction or is the contra-side in a locked-in (QSR) submission. On the Summary Report, these sides are deducted from the total satisfactory/ questionable count for computing lateness.[6] (Note that to be in this category, any buy-side submission must be designated as a “Target Syndicate” submission. Buy-side submissions against RTTM Syndicate Takedown (ST) sales are optional. If a buy-side submission is made as an MT515 message, the submitter must use code ITYPTS in the Trade Processing Narrative Field; to do this in an RTTM Web screen, the submitter must select “Trade Type” as “Syndicate Target.” The “List Offering Price/Takedown” (LOP/TD) Special Condition Indicator is separate and distinct from ITYPTS or Syndicate Target and the LOP/TD Indicator will not cause a trade to be in the Syndicate buy/locked-in contra category.) Invalid time: A trade is shown in this category if the reported time of trade is 00:00 or is before 06:00 or after 21:00. This count includes both customer and inter-dealer reports. See Attachment C for further details. Special conditions: A trade is shown in the category, “Away from market price - Extraordinary settlement” if the dealer reports Special Condition Indicator M200, M210 or M230. A trade is shown in the category, “Away from market price – Other reason” if the dealer reports Special Condition Indicator M900, M910 or M930. All satisfactory or questionable, matched, uncancelled trades with these Special Condition Indicators are shown whether or not they are in any other category (late, amended, etc.). Trades submitted with a Special Condition Indicator are shown on the Detail Report, even if there is no other exceptional condition (i.e., even if the trade is not late, not amended, etc.). In addition, the Special Condition Indicator itself is shown, to indicate that the dealer reported that an extended deadline or that another special condition applied to the trade. If the trade is unsatisfactory, cancelled or unmatched, however, the special condition indicator is not shown. If a Special Condition Indicator is shown, the field “Extended Deadline Text” translates it into words. For example, if M020 is shown, the report displays “Traded at list price - EOD report (list price trade by syndicate).” The Extended Deadline Text displays “Invalid Indicator” if the submitted indicator has a value RTRS does not recognize, e.g., if it has the letter “O” instead of a zero or if it is M120, M220 or M920. Weighted average price: A trade is shown in this category if the dealer reports that its price is the weighted average of previous trades. All weighted average price trades are shown whether or not they are in any other category (late, amended, etc.), provided they are satisfactory/questionable, matched, and uncancelled. Amended: A trade is shown in this category if any field listed in Attachment D was amended by the dealer. A trade is shown as amended whether it was amended in any of those fields once or more than once. Number of times amended: This shows the number of times an amendment was submitted that changed any of the fields listed in Attachment D. Reversed report: An inter-dealer trade is shown in this category if it was reversed by both parties after it was matched by RTTM. Traded flat: A trade is shown in this category if the Special Condition Indicator is M100, M110 or M130. Treatment of trades that are unsatisfactory, cancelled or unmatched: Trades that are unsatisfactory, cancelled or unmatched are identified on the Detail Report, but the above details are not shown for these trades. The report shows the identifying attributes of the trade and also shows by the presence of an “X” whether the trade is: Inter-dealer matched unsatisfactory Customer unsatisfactory Inter-dealer unmatched Cancelled In addition, the following is shown for unsatisfactory, cancelled or unmatched trades: Dealer symbol missing/unknown. As is the case for lateness or invalid time (Attachment C), even if the correct dealer symbol was later reported via an amendment, the trade is shown in this category. See “Unsatisfactory Error Codes” below. Reversals and reversed trades: A “reversal” is a submission that the dealer has indicated is a reversal and that has been matched with the contra-party’s reversal submission. Reversals offset previous matched trades. Reversals are identified in the Detail Report, but are not categorized as to lateness, etc., since they are offsets, not original reports.[7] A “reversed trade” is the previous trade that is reversed by the matched reversal. Reversed trades are identified in the Detail Report and are categorized as to lateness, amends, etc. Note that a trade is not reversed unless the two sides of the reversal both “point to” a single previous trade. If the sides of the reversal do not both have a reversal control number, or if their reversal control numbers refer to two different trades, no trade is reversed. (RTRS sends feedback on the reversal when these conditions occur. It sends Error Code U06B, “Reversal control number missing,” in the first case and Error Code Q06A, “Reversal control number missing or incorrect on your or contraparty report,” in the second. These messages on the reversal indicate that no trade was reversed.) Unsatisfactory Error Codes Trades that are unsatisfactory have an “unsatisfactory” error or errors. Examples are: U41B – UNSAT Dealer symbol missing U52B – Dealer capacity missing The codes corresponding to the various “unsatisfactory” errors are on the right side of the Transactions Report. The meaning of each code is in the comment at the top of the column. There is an “X” for each error found in the trade report. If by the end of the processing window the dealer has corrected an incorrect or missing Executing Broker Symbol, there will be no “X” under U41B or U41D (“Dealer symbol missing” or “Dealer symbol not known to the MSRB).” However, there will be an “X” in the column “Dealer symbol missing/unknown” (column T). This indicates that at one time the trade report had an unknown or absent dealer symbol. The Summary Report counts these conditions also (cell “T”). Most error conditions are not shown for reversals. However, error U06B, “Reversal control number missing,” applies only to reversals. This error indicates that the reversal submission did not include the reference number of the trade that was to be reversed. Therefore, error U06B is shown for reversals. Assigning Trades to Dealers On both the Summary and Detail Reports, inter-dealer trades are assigned to the clearing broker, not the correspondent (introducing dealer). If an inter-dealer trade is executed between two correspondents of the same clearing broker, the sale and the purchase will both be counted on the clearing broker’s reports. For example, if Dealer A sells to Dealer B, and both are correspondents of the same clearing broker, then the report for the clearing broker shows both the sale and the purchase on separate lines. Each line corresponds to a submission by the clearing broker. Customer trades are assigned to the dealer that executed the trade. This dealer is identified by the four-letter executing broker symbol, such as ABCD. Special Condition Indicator “ERR!” In early 2005, startup difficulties involving RTRS and RTTM caused a small number of inter-dealer submissions to be corrupted after they were submitted by dealers. Submissions corrupted in this way cannot be correctly identified as matched, unmatched, cancelled, late, etc.. For this reason, the MSRB has set the Special Condition Indicator of these submissions to the value ERR!. When displayed on the Detail Report, ERR! is translated into the phrase “RTRS Processing Error Caused Invalid Data.” In this case, users of the detail report should disregard any “X”s that may appear for the submission.[8] List of Attachments ATTACHMENT A Summary Report Keyed to Detail Report (spreadsheet) ATTACHMENT B Sample Detail Report (spreadsheet) ATTACHMENT C Details Regarding Lateness and Invalid Time of Trade ATTACHMENT D Significant Modifications
Revision History
Summary Report Keyed to Detail Report (spreadsheet) Sample Detail Report (spreadsheet)
Details Regarding Lateness and Invalid Time of Trade Lateness RTRS calculates the difference between the time of trade reported by the dealer and the time the report was submitted. If this exceeds the deadline, the trade is recorded as late.[9] Details of RTRS “late” processing are below. The deadline for reporting nearly all transactions is 15 minutes after the time of trade. The dealer may indicate that another deadline applies to the trade by submitting a Special Condition Indicator, as follows: M100, M200, M900 (or no Indicator) 15 minutes M010, M110, M210, M910 3 hours [scheduled to sunset 12/06 and 12/07] M020 EOD [list price, syndicate or takedown trade] M030, M130, M230, M930 EOD [security with < 9 months effective maturity] How RTRS Identifies Late Submissions RTRS compares the trade date and trade time reported by the dealer with the time the initial submission is received by RTRS or RTTM, whichever receipt time is the earlier. If the submission has no valid Special Condition Indicator or has M100, M200 or M900 and is received more than 15 minutes after the reported time and date, it is tabulated as “late.” If the submission has M010, M100, M210 or M910 (which indicate that the dealer has not traded the security in the past year and does not have a description of the security in its reference file), and is received between 15 minutes and three hours after the reported time and date, then RTRS verifies whether the dealer has traded the security in the past year. If the dealer has traded the security in the past year, or if the submission is received more than three hours after the reported time and date, it is tabulated as “late.”[10] Finally, if the submission has any other Special Condition Indicator and is received after the end of the trade date, RTRS tabulates it as “late.” RTRS does not verify the effective maturity of the security, whether the trade was at list price or if the dealer is a member of the syndicate. Amending Time of Trade The dealer may amend the time of trade. The amendment may make the trade “late,” but cannot change a “late” trade to make it “not late.” Examples, using the 15-minute deadline: Example 1 Initial report made: 10:00 - Reported time of trade: 09:50 - Trade is “not late” Amend time of trade to: 08:50 - Trade is “late” Example 2 Initial report made: 10:00 - Reported time of trade: 08:50 - Trade is “late” Amend time of trade to: 09:50 - Trade is still “late” Amending a Special Condition Indicator The dealer may amend the report to add or drop the Special Condition Indicator. Dropping the Indicator may make the trade “late.” Adding an Indicator or changing one Indicator to another does not change a “late” trade to make it “not late.” Example 3 Initial report made: 12:00 - Reported time of trade: 09:50 – Indicator M030 - Trade is “not late” Amend the report, dropping the Indicator - Trade is “late” Example 4 Initial report made: 12:00 - Reported time of trade: 09:50 – No indicator reported - Trade is “late” Amend the report, adding Indicator M030 - Trade is still “late” Invalid Time of Trade A trade is shown in this category if the reported time of trade is 00:00 or is before 06:00 or after 21:00. The time of trade must be expressed as military time (and reported as Eastern time). A dealer reporting, for example, the invalid time 03:00:00 probably intended to report 15:00:00 hours, which is 3:00 pm. If the reported time of trade is inaccurate, the dealer must amend the report to show the accurate time. However, the trade will remain in the “invalid time” category after the amendment. Significant Modifications A trade is shown as amended if the dealer has modified any of the following fields. A change to a field that is not in this list, such as contra-party capacity, is not considered “significant” in RTRS and does not cause the trade to be shown as amended. Trade date Trade time Trade type (Buy/Sell) Target indicator Submitter CUSIP Par Settlement date adjustment Commission Dollar price (if this was provided in the initial report of the trade) Yield (if this was provided in the initial report of the trade) Accrued interest (if this was provided in the initial report of the trade, for inter-dealer trades only) Settlement amount (if this was provided in the initial report of the trade, for inter- dealer trades only) Settlement date Dealer symbol (the dealer’s own symbol or its report of the contra-party’s symbol) Capacity Reversal indicator If a reversal, target XREF being reversed Special condition indicator Issue type Concession Trade indicator (cash/locked-in/syndicate takedown) Identifying Specific Changes The Detail Report shows each trade report in its latest state (within the processing window). To view previous reports of the trade and to see what was changed, dealers can use RTRS Web (use the Trade Information screen, Trade Information tab, and click on “Message History,” then on “Export Trade Data.” See “Real-Time Transaction Reporting System Web User Manual.”) Enforcement agency staff can view the trade history from the Surveillance Database screens/reports. Amendments to Reversals Detail Reports do not show amendments to reversals. The Summary Reports for months before February 2006 count amendments to reversals together with other amendments, so the Detail and Summary Reports will differ for that period. From February 2006 onward, neither report counts amendments to reversals. [1] The Detail Report delivered by RTRS Web is intended to be opened by Excel 2000 with Service Pack 1 or a later version. If you have an earlier version of Excel and the report does not open, call the Transaction Reporting Assistants at (703) 797-6600. [2] Rule G-14 real-time reporting requirements became effective on January 31, 2005. From January 10 to January 31, 2005, Rule G-14 end-of-day reporting requirements applied, but dealers could optionally use real-time reporting formats to prepare for the transition to real-time reporting. There are no Detail Reports for January or February 2005. [3] Error codes are listed in Appendix B.1 of the Specifications for Real-Time Reporting of Municipal Securities Transactions. See http://www.msrb.org/msrb1/TRSweb/RTRS/RTRSUsersManual.asp. [4] Information about submissions with different destination codes is available to dealers on the Destination Code Report, described in “RTRS Web Enhancements and New Reports Implemented June 14, 2005” (MSRB Notice 2005-35), on www.msrb.org. [5] Purge rules are listed in Appendix E of Real-Time Trade Matching (RTTM) for NSCC-Eligible Fixed Income Securities: Business Requirements on www.NSCC.com. [6] The dealer that is the contra-partycannot affect the timely or late reporting of trades which are reported unilaterally by the party that is on the other side of the trade. Therefore, these sides are deducted from the count used to compute lateness. However, when rates other than lateness are computed, the syndicate “buy” dealer or locked-in dealer is responsible for the accuracy of the data reported about it by the seller. Rule G-14 requires the dealer to monitor such submissions to ensure that data representing its side of the trade is correct and to use NSCC procedures to correct the trade data if it is not. The Summary Report for months before September 2005 count a syndicate buy/locked-in contra submission twice if the submission was modified after it matched. The Detail Report counts this type of submission once. From September 2005 forward, the reports count each of these submissions once. [7] Summary and Detail Reports differ in categorizing certain unusual reversals as “unsatisfactory,” “late,” etc. This happens when a participant submits a reversal record which RTTM matches with another submission that was not indicated as a reversal. Before August 2005, Summary Reports counted such reversals as “unsatisfactory,” “late,” etc. From August 2005 forward, Summary Reports do not count reversals in any of these categories. Detail Reports do not categorize reversals as “unsatisfactory,” “late,” etc. in any month. Thus, for this situation, counts in the Summary Reports may be slightly greater than counts in Detail Reports for trades processed before August 2005. [8] A submission with corrupted data may be incorrectly counted by the Summary Report also. [9] Detail Reports covering months before June 2005 will not show customer trade reports as “late” if the dealer (incorrectly) indicated the customer trade was a target submission against another trade. (Only inter-dealer trades can be targeted). From June 2005 forward, any customer trade report submitted after its deadline is “late.” [10] The three-hour exception for when, as and if issued trades ends on December 31, 2007 and for all other trades on December 29, 2006. See MSRB Notice 2005-62, “SEC Approves Proposed Rule Change To MSRB Rule G-14 RTRS Procedures, Paragraph (a)(ii)(C) to Extend the Expiration Date of the Three-Hour Exception” (December 22, 2005) on msrb.org Transaction Reporting: Notices, Real Time Transaction Reporting Documentation, | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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