The aim of this standard is to provide a foundation for greater transparency on trade workflow between all market participants and reduce end-of-day bottlenecks and manual processing.
Date
11 Nov 2022
The aim of this standard is to provide a foundation for greater transparency on trade workflow between all market participants and reduce end-of-day bottlenecks and manual processing.
We applaud FIA’s actions post Covid volatility and volume to lay the framework for the Derivative Markets Institute for Standards (DMIST), the leadership of the organization, and the industry for its participation in the exercise. We adamantly believe that understanding perspectives across the industry position participants to develop, stress test, and implement solutions. We’re appreciative of the opportunity to provide input regarding the “Standard Regarding Timeliness of Trade Give- Up and Allocation” and are excited to participate more formally in standard development and rollout moving forward.
Thank you for providing the opportunity to give feedback regarding the 30/30/30 rule.
To sum up, 9o9% of the issues all arise during the ROLL PERIODS, partially due to increased volume spike for a small time span of 2-3 days, but it is clearly exacerbated by the Point of entry via the broker.
I feel it's mostly the broker who because of speed and urgency, often neglects to put the correct learning instructions on the trade (account type/account number, open/close for each leg of the spread) which because of the urgency to "get the fill and roll for my big client" menasa the back office staff is left with an impossible amount of incorrectly allocated trades, and or missing give ups and will simply never get the time to catch up before the exchange trade EOD Cut-offs hit.
If you need more feedback, do not hesitate to reach out to me.
We are writing to comment and highlight the proposed 30/30/30 standard. As a board, we are heavily in favor of this standard. This will help reduce operational risk by ensuring trades clear in the proper account in a timely fashion. To be more specific, this will allow for a more real-time account valuation, position monitoring, margining, as well as decrease the risk related to unallocated expiring transactions. As an industry, all participants stand to benefit from this proposed standard. That being said, we would also like to highlight some of the challenges in meeting this goal.
The Global Association of Central Counterparties (“CCP12”) appreciates the opportunity to comment on the Derivatives Market Institute for Standards’ (“DMIST”) Consultation Paper: Standard Regarding Timeliness of Trade Give-Up and Allocation (“Consultation Paper”).