Record Keeping

23rd February 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 require venues to capture new data relating to orders in order for a trading venue to carry out its core activities. That information includes:

  • the identity of the trader or algorithm responsible for execution within the member or participant;
  • the identity of the trader or algorithm responsible for the investment decision within the member or participant; and
  • the identity of the immediate client of the member or participant.

This presents 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 more generally, and other trading venues across asset classes to develop a solution that it believes can be adopted as a standard.

Cboe's approach is based upon capturing short form IDs on orders, which are then supplemented with a mapping file that can be provided at another time. This mapping file, containing the underlying data, will be submitted and stored securely until the complete order records are required by a regulator.