Beginning July 10, 2017, FINRA Member Firms began reporting transactions in U.S. Treasury Securities to FINRA via TRACE (Trade Reporting And Compliance Engine).


1. Scope of Securities to be reported

On the Runs, Off the Runs, T-Bills, Notes, Bonds, TIPS and STRIPS*, and WI instruments.

*applies to the separate principal and interest components of a U.S. Treasury security that have been separated pursuant to the STRIPS program.


2. Exempt from reporting

Auction transactions, Repo and Reverse Repo transactions.


3. BTEC MPID (market participant identifier)

CLOB activity will be reported under MPID: IEBC

Stream activity will be reported under MPID: IEBD


4. Customer MPID

As of April 2019, BTEC is required to identify all its subscribers in its reports to TRACE, including all non-BD subscribers. For non-BD subscribers, BTEC will contact FINRA to obtain a FINRA assigned MPID for the subscriber. For more details, see FINRA Notice 18-34.

When a subscriber changes its regulatory status and becomes a BD, that subscriber must provide the updated MPID to BTEC in advance so that BTEC can accurately report each transaction to TRACE. 


5. What must be reported

Any transaction in a TRACE eligible security must be reported to TRACE by any FINRA member that is a Party to the Transaction. As BrokerTec Americas LLC acts as Matched Principal and is the counterparty on all transactions, BrokerTec Americas LLC will be reporting every trade as BrokerTec Buys or Sells from either another FINRA Member Firm or a non-FINRA member firm (Customer).  If the transaction is with another FINRA Member Firm, that firm will also be reporting that trade to TRACE and it must match BTEC reporting to TRACE for certain information fields.


6. Does the ATS report on an aggregated basis to account for “work-up?”

No, as of April 2019, member Firms are required to report to TRACE each transaction in U.S. Treasury securities executed in trading sessions on an ATS on a disaggregated basis. This means BTEC no longer reports all work-up sessions in aggregate; instead, as of April 2019, BTEC has been reporting each session on a disaggregated basis, resulting in greater number of transactions reported. For more information, see FINRA Notice to Members 19-03.

Note that with the change to disaggregated reporting, in any transaction in which one counterparty executes a single order against multiple counterparties, each match must be reported separately to TRACE. BTEC provides each fill via STP feed. For questions regarding setting up and permissioning the STP please contact GAM. For any technical problems with the existing STP feed please reach out to GCC.


7. Frequency of reporting

Reporting is generally required within 60 minutes of execution, but BTEC reports as soon as technologically practicable. For details on reporting obligations for UST see FINRA Rule 6730(a)(4).


8. Dissemination

At this time, FINRA will disseminate information on individual transactions in On-the-Run Nominal Coupons on an end-of-day basis, pursuant to FINRA Rule 6750(c).


9. Reportable transaction information

(1) CUSIP number or, if a CUSIP number is not available at the time of execution, a similar numeric identifier or a FINRA symbol;

(2) The size (volume) of the transaction;

(3) Price of the transaction (or the elements necessary to calculate price, which are contract amount and accrued interest) - when-issued trading is based on yield rather than on price as a percentage of face or par value thus the yield should be reported in lieu of the price;

(4) A symbol indicating whether the transaction is a buy or a sell;

(5) Date of trade execution (for “as/of” trades only);

(6) Contra-party’s identifier (MPID, customer, or a non-member affiliate, as applicable);

(7) Capacity — principal or agent (with riskless principal reported as principal);

(8) Time of execution-

(9) Reporting side executing broker as “give-up” (if any);

(10) Contra side introducing broker in case of “give-up” trade;

(11) The commission (total dollar amount);

(12) Date of settlement;

(13) If the member is reporting a transaction that occurred on an ATS pursuant to Rule 6732, the ATS’s separate MPID-

(14) Such trade modifiers as required by either the TRACE rules or the TRACE users guide.


10. Timestamps

Timestamps should be reported in UTC to the finest increment captured by the execution system. BTEC captures execution to the nearest nanosecond. But, the TRACE system does not accept trade reports in increments finer than a microsecond. Where a firm captures time in an increment finer than a microsecond, the firm must truncate the time when reporting the transaction to TRACE. See TRACE FAQ #3.5.8.


11. Trade modifiers

“.B” modifier must be appended if the transaction being reported is part of a series of transactions where at least one of the transactions involves a futures contract (e.g., a “basis” trade);

“.S” modifier if the transaction being reported is part of a series of transactions and may not be priced based on the current market (e.g., a fixed price transaction in an “on-the-run” security as part of a transaction in an “off-the-run” security).

The “.S” modifier applies more broadly than the “.B” modifier in that it applies to a trade report if the transaction being reported is part of a series of transactions that could result in the reported transaction being executed away from the current market. The “.S” modifier applies to a transaction in a particular strategy that meets the “.S” criteria regardless of whether it is, in fact, off market and is therefore permitted when a transaction is part of a series and could be, but need not be, priced away from the market.

BTEC appends all RV-curve instruments with “.S” modifier.


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All examples in this report are hypothetical interpretations of situations and are used for explanation purposes only. The views in this report reflect solely those of the author and not necessarily those of CME Group or its affiliated institutions. This report and the information herein should not be considered investment advice or the results of actual market experience.

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