Still a ways from final Dodd-Frank Rules. But we can definitely see how they are shaping up. One issue that is certain for all companies engaged in trading: Execution Time. Here’s the issue: We were working with a client using one of the larger ETRM systems. Trades are brought in through a “Quick Fix” custom set of code from ICE and NYMEX and entered into the ETRM system. Pretty straightforward. What we are certain of, based on current Dodd-Frank Rules is that Execution Time, or the time that a transaction was actually executed, is going to be a key parameter in Dodd-Frank reporting. I’d put it at 99% certainty. So here is the problem. The client’s Quick Fix connection somehow dumped execution time. The people who originally developed the solution did not think it was an important criteria and did not code it into the ETRM loading solution. Second, the target ETRM system did not really have any place to put Execution Time. Sure, you can load it into a User Defined Field. But where we really wanted it was in the Primary Position Table where we could report off of it. The only thing the ETRM offered was trade input time. But for Regulatory Reporting this is…as they say….not Kosher. It is worth taking a look at how your exchange solution might be able to feed through Execution Time to your ETRM system or wherever you plan on doing regulatory reporting.
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