TTR II User Manual V 1.3 March 2018

Transcription

1 TTR II User Manual V 1.3 March 2018

2 Document Information Contact Name Code Contact information Note Alexander Racher AR Roland Rotsejdl RR Revision History Version Status Date Editors Description 1.0 F AR Final Version 1.1 F AR Complete makeover, see marked changes in corresponding markup version document 1.2 F AR Some smaller updates 1.3 F AR Updates due to bug fixes according to customer feedback in production Legend: WIP: Work in progress R: To be reviewed F: Approved User Manual TTR II (V1.3) Page 2 / 56

3 Table of Contents Document Information Introduction, Basics and Expected Functionalities Abbreviations and terms Asset Classes to be considered Data input Automated data input via FIX Interface Messages for Pre Trade Publishing Messages for Post Trade Transparency Messages for Portfolio Compression Cycle Manual data input via WebGUI ESMA Instrument Search / TOTV Check Data Input Checks General Input Checks Check against ESMA DB Who-needs-to-report Reporting delay check Legal Entity Identifier (LEI) Data Processing Normal processing Publication delay check Exception processing Trade flags Deferred publishing = Waiver Concept Deferrals for equity and equity-like instruments Deferrals for non-equity instruments Combinations of Trade Flags Combinations of Trade Flags Equity RTS Combinations of Trade Flags Non-Equity RTS Data correction possibilities Data Output ADH Tip/Fix Converter Website Display of TTR II transactions on website (15 minutes delayed) Display of public information to the TTR II system on website Information to be made public Pre-Trade Reporting Post-Trade Reporting Acceptable reporting delays for equity and equity-like instruments Acceptable reporting delays for non-equity instruments Portfolio Compression Cycle Data Storage Reporting Reporting to Customers Trade Details Report User Manual TTR II (V1.3) Page 3 / 56

4 Price Offer & Quote Details Report Portfolio Compression Cycle Details Report SI Status Report Means of report generation Display of automatically generated reports within GUI Submenu Report Overview Manually generated reports within GUI Submenu Report Generation (Advanced Reporting) Reporting to National Capital Market Authority (FMA) General reporting obligations to FMA User Manual TTR II (V1.3) Page 4 / 56

5 1. Introduction, Basics and Expected Functionalities TTR II is a MiFID II compliant transaction reporting /publication system, allowing customers of Wiener Börse AG to report OTC trades, price offers / quotes and portfolio compression cycles (PCCs). In the course of MiFID II / MIFIR (hereinafter MM ) transparency obligations for off-exchange transactions will be enhanced massively. MM now defines more financial institutions as Systematic Internalisers (SI) and at the same time defines rules, which information on their trading actions they have to publicly disclose. Besides the more rigid obligations for SIs all other financial institutions have to report their OTC activities not only in equities but all other instrument classes as well (fixed income / bonds, structured products, derivatives, ). Current WBAG solution for MiFID I is called Transparency Trade Reporting (TTR ) and focuses primarily post-trade data in equities. Future solution Transparency Transaction Reporting II (TTR II) includes post-trade publication for all equity and non-equity asset classes and pre-trade publication as well. MM furthermore defines the Approved Publication Arrangement (APA), entities, which are allowed to offer OTC publication services to financial institutions within the EU. In order to become an APA, an entity has to apply at its National Capital Market Authority (NCA, in Austria: FMA). WBAG will offer the data to all interested stake holders in FIX protocol format (hereinafter Tip/Fix Converter ). For this a FIX feed is set up and is feeded with ADH data. This allows offering the full scope of WBAG s and its partner exchange s data products also via FIX to interested customers. Legal documents used for this functional description: MiFID II_RL EU_ _CELEX-32014L0065-EN-TXT.pdf MiFIR_Regulation (EU) No _ _CELEX-32014R0600-EN-TXT.pdf RTS 1, 2, 3, 13 and 14 (parts of other RTS docs used in the text as well) Many data correctness checks are done against the ESMA reference data base (FIRDS) as currently available for MiFID I OTC reporting. ESMA will substantially extend this DB for all non-equity reference data. User Manual TTR II (V1.3) Page 5 / 56

6 The overview of the TTR II workflow of data input, data processing and data publishing is shown in the figure below: Figure. 1: TTR II data processing User Manual TTR II (V1.3) Page 6 / 56

7 Application language The language of the TTR II application is English Abbreviations and terms Abbreviation, Term FIX FMA MiFID OTC PCC ESMA DB / FIRDS Description Financial Information exchange Protocol Finanzmarktaufsicht (Austria s NCA) Markets in Financial Instruments Directive Over the counter Transactions executed outside of a trading venue Portfolio Compression Cycle European Security and Markets Authority Database / Financial Instruments Reference Data System 2. Asset Classes to be considered Resources: MiFIR Regulation , Article 20 and 21 The TTR II system allows the processing and publication of trades, price offers, quotes and PCCs for all asset classes. Please refer to the tables below for details. a) Equity and equity-like financial instruments (Annex III to RTS 1) Asset Class MiFIR Code ADH BasicDataType Shares SHRS BDSh ETFs ETFS BDEt Depositary Receipts DPRS BDSh Certificates (funds, no structured products as defined by WBAG) CRFT BDEt Other equity like financial instruments OTHR BDSh User Manual TTR II (V1.3) Page 7 / 56

8 b) Non-equity financial instruments (Annex IV to RTS 2) Asset Class MiFIR Code ADH BasicDataType Securitised derivatives SDRV BDUt Structured Finance Products (SFPs) SFPS BDUt Bonds BOND BDBo ETCs ETCS BDBo ETNs ETNS BDBo Emission Allowances EMAL BDSh Derivative DERV BDDe 3. Data input Two different data input sources for TTR II are available: 1) Automated data input via FIX Interface (dedicated TTR II FIX interface) 2) Manual data input via WebGUI A defined set of fields shall be inserted by the customer via FIX and WebGUI for further publication. More information can be found in the following separate specifications: - CEESEGFIX TTR II Specification - WebGUI Specification As a further improvement it is planned to automatically populate the dataautomatic population of thesome fields available inon basis of the ESMA DB within the WebGUI (the customer only has to insert the instrument identifier fields). ) is implemented. More details can be found within the separate Excel specification of the WebGUI. The same applies to the FIX interface. In case it is not possible to use ESMA DB data, the sent transaction is rejected in case mandatory fields are missing. Note: As FIRDS Reference and Transparency data do not deliver all fields as necessary for a new transaction (MiFIR Instrument Types), customers do need to enter this according to the following overview: Code Meaning InstrumentTypeMiFIR Equity financial instruments (Annex III to RTS 1): SHRS shares ETFS ETFs DPRS depositary receipts CRFT certificates (funds, no structrured products as defined by WBAG) User Manual TTR II (V1.3) Page 8 / 56

9 OTHR other equity like financial instruments Non equity financial instruments (Annex IV to RTS 2): SDRV Securitised derivatives SFPS Structured Finance Products (SFPs) BOND Bonds ETCS ETCs ETNS ETNs EMAL Emission Allowances DERV Derivative InstrumentUnderlyingTypeMiFIR for SDRV and DERV INTR Interest rate EQUI Equity COMM Commodity CRDT Credit CURR Currency EMAL Emission Allowances EMALSubTypeMiFIR for EMAL and DERV/EMAL Emissions Allowances ( EMAL ) sub type CERE CER ERUE ERU EUAE EUA EUAA EUAA OTHR Other InstrumentSubTypeMiFIR for DERV OPTN Options FUTR Futures FRAS Forward Rate (FRA) Agreement FORW Forwards SWAP Swaps PSWP Portfolio Swaps SWPT Swaptions FONS Futures on a swap FWOS Forwards on a swap FFAS Forward Freight Agreements (FFAs) SPDB Spread betting CFDS CFD OTHR Other User Manual TTR II (V1.3) Page 9 / 56

10 3.1. Automated data input via FIX Interface The FIX communication is elaborated in detail in the CEESEG FIX TTR II specification Messages for Pre Trade Publishing For pre trade transparency the following messages are defined: New Order Single Cancel Order Request Cancel Replace Order Request Execution Report Quote Quote Status Report Note all pre-trade messages ( orders and quotes ) are only valid for the current trading day Messages for Post Trade Transparency For post trade transparency the following messages are defined: Trade Capture Report Trade Capture Report Ack Kindly note TTR II requires customers to send the correct turnover (only in EUR!) for each trade in following cases (conditionally mandatory in FIX): 1. LRGS equity post-trade transparency waiver for deferred publication 2. Customer uses SI-threshold calculation Turnover needs to be updated in the course of trade corrections if price or volume were changed! Furthermore changes of ISIN may only be done via cancellations / send new trade, there is no trade correction of ISIN possible Messages for Portfolio Compression Cycle For PCC the following messages are defined: NewOrderList ExecutionReport 3.2. Manual data input via WebGUI For manual data reporting a WebGUI is implemented with the following functionalities: Entry of transactions (trades, price offers, quotes, PCCs) Overview of all reported / published transactions Correction of transactions Deletion of transactions User Manual TTR II (V1.3) Page 10 / 56

11 Downloading of predefined reports Generation of individual reports Waiver view ESMA Instrument Search / TOTV Check FIRDS The WebGUI is implemented in HTML5, available via HTTPS and secured via TLS. The WebGUI will be available in production via the URL in production and in simulation. Kindly note TTR II requires customers to send the correct turnover in EUR for each trade in following cases (conditionally mandatory in WebGUI): 1. LRGS equity post-trade transparency waiver for deferred publication 2. Customer uses SI-threshold calculation Turnover needs to be updated in the course of trade corrections if price or volume were changed! Furthermore changes of ISIN may only be done via cancellations / send new trade, there is no trade correction of ISIN possible. Data input via WebGUI shall be done always in local time, TTR II takes care of conversion to UTC ESMA Instrument Search / TOTV Check Depending on the availability, functionality and detailed content of the ESMA Database (FIRDS), WBAG will provideprovides an additional service called TOTV Check. In general, the TOTV check in FIRDS shall provide an enhanced search possibility, which is offered to customers as a separate service. With the help of this search customers shall have the possibility to check, if certain instruments (derivatives) are traded on a trading venue within the EU (TOTV) and are therefore mandatory to be published. More details on the TOTV check may be found in the separate Excel specification Editing or deleting of data within WBAG s database ESMA Download DB, where all data from ESMA DB (FIRDS) is stored, is not possible any more (in comparison to the old TTR system), as there will be a possibility to skip the ESMA check when entering transactions. Please refer to the separate specifications for the WebGUI and FIX for more information on this functionality. User Manual TTR II (V1.3) Page 11 / 56

12 4. Data Input Checks Resources: DVO 2017/571 (RTS 13): Article General Input Checks Applicable to: Pre-trade Post-trade Resources: MiFID2 Directive , Article 64 RTS 13 Paragraph 14 RTS 13 Paragraph 25 RTS 13 Article 10 Paragraphs 4-8 Within FIX and the WebGUI some general checks are implemented. The subsequent fields are checked for validity. Please note: Any checks are only triggered after the customer hits the send button in the GUI respectively sends the FIX trade report. Depending of the result of the checks, the report is sent to the TTR II system or rejected (with corresponding rejection message). Excluded are of course any fields, where the customer can only select from dropdown menus in the GUI. The same applies for FIX in cases where only a predefined set of valid values is accepted. Mandatory fields All mandatory fields according to the CEESEG FIX TTR II specification respectively the WebGUI specification shall be populated by the customer. Otherwise the reporting of the transaction is not possible within the GUI and in case of FIX the message is rejected. InstrumentIdentifierTypeISIN (FIX tag 2248) Mandatory field. Valid value: ISINA In case of mismatch for FIX, a rejection is triggered; the WebGUI uses ISIN per default. ISIN (FIX tag 48) Mandatory field. In case the field InstrumentIdentifierType is ISIN, a check, if the inserted ISIN is valid, is implemented. The checks are done according to ISO 6166 and include: User Manual TTR II (V1.3) Page 12 / 56

13 o Length of the ISIN is 12 characters o The last character (12) is the check sum Please use the standard feature of quick fix for this check (also for the GUI). In MiFID II mentioned code OTHR became obsolete as all instruments in FIRDS have to have an ISIN. Price (FIX tag 44 in Order messages, tags 132 and 133 in Quote messages, tag 31 in Trade message) The inserted price needs to numeric according to RTS 1&2 (decimal 18, 17) and is mandatory. Explanation for the format decimal 18,17 : According to MiFID II this notation means there is a maximum of 18 digits in total, whereas up to 17 digits may be used after the decimal point. Exceptions: 1.) In case of pending prices the price field may also be empty (NULL). The pending price information is then transported in a separated field. For more details see CEESEG FIX TTR II specification. This is a mandatory requirement from MiFID II. The purpose of a pending price: In case of forward pricing, a trade is done without the price being known. Therefore the price is published with NULL (not 0) and a corresponding flag PNDG (=Pending Price; only a flag, not a price!). Investment firms are obliged to publish the missing price in form of a correction of the originally reported trade as soon as possible. 2.) In case of supplementary deferral flags DATF (2672=12), VOLW (2672=16), COAF (2672=21), FWAF (2670=11) or IDAF (2670=15) the price is not checked, as the customer has to send a VWAP for aggregated transactions instead. Date & Time of transaction (tag 60) The inserted date & time shall not be in the future. In general for publication the MiFID II compliant Date_Time shall be published: YYYY-MM-DDThh:mm:ss.ddddddZ (Z=UTC) For thethe customer this implies the following:does not need to insert MiFID II compliant Date_Time fields. o Via FIX the customer sends the format YYYYMMDD-hh:mm:ss.ddd. according to the FIX specification. The timestamp is UTC as per FIX specification. Please note, the Z is redundant in FIX, but mandatory any way. As not the complete time stamp is delivered via FIX, the timestamp is filled by the APA system before publication. o Via WebGUI the customers sendenters the format YYYY-MM- DDThh:mm:ss.ddddddZ. The separatorsdd and the letters T and Z are prefilled within the WebGUI.hh:mm:ss. The dddddd are prefilled with , however, they may be changed if necessary. User Manual TTR II (V1.3) Page 13 / 56

14 The date & time inserted by the customer shall be granularconversion to at least the nearest second. o It is expected, that the customers converts thea MiFID II compliant time stamp as well as to UTC time before entering it.is done by the TTR II system. The following MiFID II affected time stamps are necessary: - Trading Date Time (to be consistent within the system, we use the format for price offers and quotes as well, not only for trades) - Publication Date Time Side-Note: Within TTR II no timestamp according to MiFID II date_time format needs to be generated. The relevant MiFID II timestamps are either inserted by the customer (according to the definition above) or generated by ADH (publication time stamp). In case there are further timestamps, which are generated within TTR II, the format is not necessarily the MiFID II format. Currency (tag 15 in all message types used) The inserted / selected currency is checked against the ISO 4217 standard in FIX. Within the WebGUI the check is not necessary, as the currencies are available in a dropdown. ID (Trade Report ID as TIC in tags 37, 20050, for Orders and Quotes, tag 880 for Trades, CLOrdID in tag 11, QuoteID) For each transaction a unique ID must be inserted / assigned by the customer. The uniqueness is checked automatically by the system. The transaction identification code, TIC, customer identification code CIC and quote identification code QuoteID shall be unique, consistent and persistent per ISO segment MIC and per trading day. InstrumentTypeMiFIR (tag 12000) Mandatory field; if missing or invalid, a rejection is triggered. This check is only relevant for FIX, as the GUI has a dropdown with all available values. Valid values: Equity financial instruments (Annex III to RTS 1): SHRS, ETFS DPRS CRFT OTHR Non-equity financial instruments (Annex IV to RTS 2): SDRV, SFPS, BOND, ETCS, ETNS, EMAL, DERV InstrumentUnderlyingTypeMiFIR (tag 12001) Conditionally mandatory field if InstrumentTypeMIFIR is SDRV or DERV. User Manual TTR II (V1.3) Page 14 / 56

15 If missing or invalid, a rejection is triggered. This check is only relevant for FIX, as the GUI has a dropdown with all available values. Valid values: INTR, EQUI, COMM, CRDT, CURR, EMAL InstrumentSubTypeMiFIR (tag 12002) Conditionally mandatory field if InstrumentTypeMIFIR is DERV. If missing or invalid, a rejection is triggered. This check is only relevant for FIX, as the GUI has a dropdown with all available values. Valid values (with explanation): OPTN = Options, FUTR = Futures, FRAS = Forward Rate (FRA) Agreement, FORW = Forwards, SWAP = Swaps, PSWP = Portfolio, SWPT = Swaptions, FONS = Futures on a swap, FWOS = Forwards on a swap, FFAS = Forward Freight Agreements (FFAs), SPDB = Spread betting, CFDS = CFD, OTHR = Other VolumeTraded Quantity (tag 38 in Order messages, tags 134 and 135 in Quote messages, tag 32 in Trade messages) The inserted volumetraded Quantity needs to be numeric according to RTS 1 and 2 (decimal 18, 17). The field volumetraded Quantity is only mandatory for equities (in any case) and for nonequities only, if the instrument is not o a commodity derivative (Instrument Type MiFIR = DERV & Instrument Underlying Type MiFIR = COMM), or o emission allowance derivatives (InstrumentTypeMiFIR is neither =DERV nor & InstrumentUnderlyingTypeMiFIR=EMAL.), or o emission allowances (InstrumentTypeMiFIR=EMAL). Explanation for the format decimal 18,17 : According to MiFID II this notation means there is a maximum of 18 digits in total, whereas up to 17 digits may be used after the decimal point. QuantityInMeasurementUnits (tag 1147) Conditionally mandatory field for instruments, for which the following combinations of classifications are applicable: InstrumentTypeMIFIR InstrumentUnderlyingTypeMiFIR DERV COMM DERV EMAL EMAL - If the field QuantityInMeasurementUnits is missing or invalid, a rejection is triggered. User Manual TTR II (V1.3) Page 15 / 56

16 NotationMeasurementUnit (tag 12007) The check is only done in FIX, as within the WebGUI the fields are filled automatically. In Conditionally mandatory field for instruments, for whichfix it is checked, if a valid combination is inserted. For the following combinations of classifications are applicable: TOCD or Free text has to be provided. InstrumentTypeMIFIR InstrumentUnderlyingTypeMiFIR DERV COMM DERV EMAL EMAL - In all other cases UNITS is the valid value. If the field NotationMeasurementUnit is missing or invalid, a rejection is triggered. Valid values: o UNITS o TOCD tons of carbon dioxide equivalent or o Otherwise <Free Text> {ALPHANUM-25} Open question to FMA on codes for Otherwise sent. Price notationnotation (e.g. percentage notation ) (tag 423) The field is mandatory for non-equity instruments with InstrumentTypeMIFIR = SDRV, SFPS, BOND, ETCS, ETNS, EMAL, DERV. Possible values: o MONE - Monetary o PERC - Percentage o YIEL - Yield o BAPO - Basis Points In case of mismatch, a rejection is triggered. Reprint (tag 570) The field is mandatory. Valid values: ORGN, DUPL In case of mismatch, a rejection is triggered. VenueOfExecution This field is only relevant for publication via ADH and is derived from tag 448 (if NO for both fields XOFF, if at least one YES SINT).Customers do NOT have to provide this, only tag 448 to highlight if on buy or sell side an SI is involved. Explanation: User Manual TTR II (V1.3) Page 16 / 56

17 Reprint (tag 570) The field is mandatory. Valid values: ORGN if not reported on any other APA and customer is responsible for reporting. DUPL if other party has to report / trade was reported at another APA earlier. Note any trade reports using DUPL are not published (not forwarded to ADH for publication) but only processed for SI threshold calculation service! Note TTR II accepts DUPL for nonequity instruments for the purpuose of SI calculations although DUPL is not specified in RTS 2 / for non-equity instruments. Nominal Value (tag 231 ContractMultiplier) The field is mandatory for non-equity instruments with InstrumentTypeMIFIR = SDRV, SFPS, BOND, ETCS, ETNS, EMAL, DERV In case of mismatch, a rejection is triggered. Nominal Currency (tag 10015) The field is mandatory for non-equity instruments with InstrumentTypeMIFIR = SDRV, SFPS, BOND, ETCS, ETNS, EMAL, DERV In case of mismatch, a rejection is triggered. Type (FIX: tag EMALSubTypeMiFIR; WebGUI: EMAL Sub Type MiFIR) Conditionally mandatory field for instruments, for which the following combinations of classifications are applicable and result in following valid values: InstrumentTypeMIFIR InstrumentUnderlyingTypeMiFIR Valid values DERV EMAL EUAE, CERE, ERUE or EUAA, OTHR EMAL - EUAE, CERE, ERUE or EUAA, OTHR In case of mismatch, a rejection is triggered. Transaction To Be Cleared (tag 577 ClearingInstructions) The field is mandatory for derivatives (InstrumentTypeMiFIR = DERV). In case of mismatch, a rejection is triggered. TTR II rejects any reports which do not fulfil the requirements. In case a check is unsuccessful, the reported transaction is rejected. User Manual TTR II (V1.3) Page 17 / 56

18 4.2. Check against ESMA DB Applicable to: Pre-trade Post-trade TTR II performs checks against the ESMA DB before accepting a new report. These checks depend on the availability of an according reference in ESMA DB. According to the national authority FMA an APA does not have to check each and every input. The checks are therefore performed with best effort. To fulfill the best effort approach, the following process is implemented within TTR II: By default each transaction is being checked against the ESMA DB. In case of a rejection caused by a mismatch of information or by a lack of information in ESMA DB, the customer has two possibilities to proceed: The customer can double check the entries and sends a corrected report. In case the information is correct from the customer s point of view, the affected transaction shall be sent with the Skip ESMA Check flag. More details to rejection messages can be found in chapter 5.3. Fields to be checked against ESMA DB Depending on the FIRDS download files made available, the fields to be checked may be updated. The criterions for the checks are taken from a parametrization, which can be configured by WBAG. Instrument Identifier (ISIN) If ESMA check is used (check box in GUI ticked or FIX tag 22 sent with value 4 ) and the inserted instrument identifier does not match the ESMA DB, a rejection is triggered. Following FMA confirmation from Sept 21, 2017 only ISINs are applicable. Nominal Currency (tag 15) ItIf ESMA check is checked, ifused and the inserted instrument exists in ESMA DB with the providednominal currency. (only mandatory for non-equity instruments) does not match the ESMA DB, a rejection is triggered. If the instrument exists with multiple currencies, Nominal Value If ESMA check is used and the inserted currency is considered for the rest of the ESMA checks, e.g. price, turnover. Price (FIX tag 44 in Order messages, tags 132 and 133 in Quote messages, tag 31 in Trade message) User Manual TTR II (V1.3) Page 18 / 56

19 i.e. max. deviation in percent compared to the ESMA reference price Tier 1: (-30% < x <= -50% OR +80% < x <= +100%) publication with warning Tier 2: (x > -50% / x > +100%) rejection This check is skipped in case that PricePending is set to YES (no price information available) or PostTradeTransparencyWaiver is - DATF (Daily aggregated transaction flag) - VOLW (Volume omission flag) - COAF (Consecutive aggregation flag) - FWAF (Four weeks aggregation flag) - IDAF (Indefinite aggregation flag) Turnover (tag 381 GrossTradeAmt, only if sent by customer) i.e. max. deviation in percent compared to the ESMA average daily turnover Tier 1: (-30% < x <= -50% OR +80% < x <= +100%) publication with warning Tier 2: (x > -50% / x > +100%) rejection This check is skipped in case that MiFID2TradeFlag or PostTradeTransparencyWaiver is - LRGS (Large in scale) or - SIZE (Transactions above the standard market size) or - LMTF (Limited details flag) or - DATF (Daily aggregated transaction flag) - VOLO (Volume omission flag) or - VOLW (Volume omission flag) Price notation (e.g. percentage notation ) (tag 423) If the inserted price notationnominal value (only mandatory for non-equity instruments) does not match the ESMA DB, a rejection is triggered. InstrumentTypeMiFIR (tag 12000) If the inserted InstrumentTypeMiFIR does not match the ESMA DB, a rejection is triggered. InstrumentUnderlyingTypeMiFIR (tag 12001) If the inserted InstrumentUnderlyingTypeMiFIR does not match the ESMA DB, a rejection is triggered Who-needs-to-report Check Applicable to: Pre-trade Post-trade For this check the following mandatory input fields need to be filled by the customer (tags 453/452/448/570): User Manual TTR II (V1.3) Page 19 / 56

20 - SI status of customer (stati: SI, Non-SI) - SI status of counterpart (stati: SI, Non-SI) - Side of the customer (stati: Buyer, Seller) - Reprint (stati: ORGN, DUPL) tag 570 Description of check: It is checked, if the customer is obliged to report or not and if the customer filled the field Reprint correctly. - In case the customer is obliged to report, he has to fill the field Reprint with ORGN In case the customer is not obliged to report, he CAN report optionally, but only with field Reprint = DUPL Originally TTR II only covered checks / automatic population of tag 570 Reprint (ORGN / DUPL) for trades between MiFID II Investment Firms (IF). In latest ESMA Q&A on transparency 35_qas_transparency_issues.pdf / Chapter 2, Answer 3a) ESMA explains the obligation in other cases (IF against client which can be a private investor or corporate - both not covered by MiFID II obligations and delegated publication): As TTR II cannot know each individual role of all included parties automatic population of field Reprint with ORGN or DUPL is discontinued. Instead, customers can enter following fields freely but are then fully responsible for the correct population of all fields: Buy / Sell / Undisclosed Client and Client Counterparty SI-Status ORGN / DUPL All mentioned fields stay mandatory as on ADH we deduct the Venue of Execution from population of field 448, all other fields are mandatory following MiFID II. o o WBAG strongly recommends reporting also DUPL transactions in order to enable a correct SI status calculation in the system. DUPL trades are not published, they are only stored in the TTR II data base. Check, who has to report: User Manual TTR II (V1.3) Page 20 / 56

21 2 non SI s seller 2 SI s seller SI = buyer, non-si = seller buyer SI = seller, non-si = buyer seller) Buyer Non-SI SI SI Non-SI (green: obliged to report) Seller Non-SI SI Non-SI SI Process of check: 1.) Customer fills the mandatory input fields (SI status customer, SI status counterpart, Side, Reprint) 2.) Customer sends the transaction 3.) The system performs the following checks: a. If customer = SI and customer = seller => Reprint has to be populated with ORGN b. If customer = Non-SI and customer = seller and counterparty = Non-SI => Reprint has to be populated with ORGN c. If customer = Non-SI and customer = seller and counterparty = SI => Reprint has to be populated with DUPL d. If customer = Non-SI and customer = buyer => Reprint has to be populated with DUPL e. If customer = SI and customer = buyer and counterparty = SI => Reprint has to be populated with DUPL f. If customer = SI and customer = buyer and counterparty = Non-SI => Reprint has to be populated with ORGN 4.) In case everything is fine, the reported transaction is processed within TTR II. In case the field Reprint was populated wrongly by the customer, the transaction is rejected with an according error message. Please note: The SI status of the customer, which is calculated by the SI check described herein, is NOT automatically used by the system. The information about the SI status of the customer has only informational character. TTR II can only monitor SI status if all trades done (incl. DUPL) by an APA customer are actually sent to ADH. Furthermore the check on Substantial Basis / comparison with customer turnover (on- and offexchange) in one specific instrument can only be done on customer side. This APA documentation holds threshold values as specified in chapter for customer turnover. DISCLAIMER: Kindly note WBAG cannot take any legal responsibility for these SI calculations. User Manual TTR II (V1.3) Page 21 / 56

22 4.4. Reporting delay check Applicable to: Pre-trade Post-trade This check only applies for transactions, which have to be published immediately (NO deferral waivers applicable). If the time difference between the trade matching (time-stamp of trade provided by customer, tag 60) and the reporting time (time of reception in TTR II, returned to the customer in tag 60) of the trade exceeds the limits defined in and 7.2.2, the affected message is not rejected, but triggers a warning flag in the reply message of TTR II as defined in chapter 5.3. Accordingly TTR II issues a warning if an equity instrument reporting time stamp is more than 1 min later than the timestamp trade matching (time-stamp of trade provided by customer) if a non-equity instrument reporting time stamp is more than 15 min (as of Jan 1, 2020: 5 min) later than the timestamp trade matching (time-stamp of trade provided by customer) The trade is published immediately if such a warning is issued nonetheless. Equity and equity-like only: All late reporting warnings only apply from 9:00-17:45 (trading hours of WBAG). If a transaction takes place outside of trading hours, then warning is issued that the trade is published at or after 9:00 (beginning of trading) of the following trading day. Please note: This check only helps in case a customer is too late with reporting a transaction. For the limits defined in and of course also the difference between the trading time and the publication time (= reporting time + TTRII processing) is relevant, see chapter 5.2. Furthermore note that for trade corrections and cancellations no reporting delay check applies. Please note that for trade corrections and cancellations no reporting delay check applies Legal Entity Identifier (LEI) Applicable to: Pre-trade Post-trade The Legal Entity Identifier (LEI) is a 20-character, alpha-numeric code, to uniquely identify legally distinct entities that engage in financial transactions. Systematic Internalisers (SI) are obliged to disclose their identity when publishing price offers or quotes (Regulation C(2016) 2860). User Manual TTR II (V1.3) Page 22 / 56

23 Please note: Only SI s are obliged to report pre-trade information, therefore the LEI has to be published in any case for pre-trade. Process: - If a new customer is registered for TTR II, also the LEI is stored once within the database. Therefore the customer doesn t need to insert the LEI with every pre-trade transaction reported, as it is already stored in the database. - The customer needs to inform WBAG via the contract and WBAG sets up the LEI - This can be done for all customers. However, the system publishes the LEI only in case of pre-trade. 5. Data Processing This chapter describes the processing of transactions within the TTR successfully passed all checks as described in the previous chapter. II system, after they have 5.1. Normal processing Resources: RTS 13 Article 10 RTS 13 Recital 17 Definition of necessary fields for normal processing: TIC Code (in tags 37, 20050, for Orders and Quotes, tag 880 for Trades): TTR II generates unique ID s. To facilitate reliable communication between an APA and the customer reporting a transaction, particularly in relation to cancellations and amendments of specific transactions, an APA should include in the confirmation messages to the reporting customer the Transaction Identification Code (TIC), which has been assigned by TTR II when making the information public. An APA shall refer to the TIC in any subsequent communication with the customer in relation to a specific trade report. This means all TTR II customers need to be able to store the TIC and provide it with any cancellation or amendment of the originally reported data. Processing Steps: 1. Customer sends trade, price offer / quote or PCC 2. TTR II generates a TIC (Transaction Identification Code) for the transaction. (NOTE: Following ESMA Q&A on Transparency a TIC shall not be generated if one of the following flags for initial aggregated publication is used: DATF, VOLW, FWAF or IDAF.) User Manual TTR II (V1.3) Page 23 / 56

24 a. TIC Code is generated uniquely. It is generated as described below: The TIC code comprises up to 52 characters and it is generated as a combination of the reportingtrading date, the reportingtrading time stamp and a sequence number, which is unique for each reporting day. b. Besides this no amendment or further enrichment of the inserted customer data takes place 3. Performance of data input checks as defined in chapter TTR II confirms acceptance of transaction (in tag 150) as ACCEPTED = PENDING_NEW OR rejects in case of missing or wrong input data as REJECTED (both including TIC). In case of duplicate trades (flagged with DUPL ) these shall not published. Reception of correct trade in TTR II are confirmed with ACCEPTED = NEW. There is no further processing but for SI threshold calculations for trades flagged DUPL. 5. Check for deferral logic Before publishing the transaction, the TTR II system checks, if potential deferrals are applicable. For more details, please refer to chapter Enrichment with defined reference data from ESMADB. (please see the WebGUI specification respectively the CEESEG FIX TTR II specification for more details on the enriched data). Generation of Basic Data Message for ADH (technically mandatory, no functional impact on TTR II) is done on ADH side. 7. Sending reported data from TTR II to ADH for publication: a. Sending & immediate publication i. Sending of reported data incl. TIC to ADH b. Queuing, deferringdeferring and sending publication i. QueuingDeferring of reported data, incl. TIC ii. After the end of the deferral time, the publication is triggered through a scheduler process, please refer to Feedback Loop As ADH is used as the publishing system for TTR II a feedback loop is set up to confirm dissemination to TTR II customers. An ADH TTR II customerfeed handler (part of TTR II) constantly monitors ADH output and checks, if ADH published the received TTR II transaction. If a TTR II transaction is received from ADH a confirmation is sent to the TTR II customer ( PUBLISHED = NEW ). Please note: TTR IIThe APAConnector sends a TIC Code and a sequence number (ApplSeqNum=1181) to the ADH system. Only with the help of these two fields a transaction may be marked as unique. Those two fields arehave to be sent back from ADH to the TTR IIAPAConnector, to be able to identify the transactions of the TTR IIAPAConnector uniquely. The sequence number is generated by the TTR IIAPAConnector and is unique per day. If a transaction is deferred for more than one day, the same mechanism applies, as the sequence number is only added while sending to ADH. User Manual TTR II (V1.3) Page 24 / 56

25 Please note: ADH data (as the data dissemination system for TTR II) is only available one way. There is no possibility to manipulate pre- or post-trading data Publication delay check Applicable to: Pre-trade Post-trade Please note: The check described hereafter is very similar to the check described in chapter 4.4 ( reporting delay check ). The main difference is: the reporting delay check from chapter 4.4 refers to a possible late reporting by the customer. The hereafter described publication delay check refers to a potential late publishing caused by a late TTR II processing. The publication delay check only applies for transactions, which have to be published immediately (NO deferral waivers applicable). If the time difference between the trade matching (time-stamp of trade provided by customer, sent in tag 60) and the publication time (returned to customer in tag 60 in published message) of the trade exceeds the limits defined in and 7.2.2, a warning as defined in chapter 5.2 is triggered together with the final publication confirmation after the processing of the feedback loop. Accordingly TTR II issues a warning if an equity instrument publication time stamp is more than 1 min later than the timestamp trade matching (time-stamp of trade provided by customer) if a non-equity instrument publication time stamp is more than 15 min (as of Jan 1, 2020: 5 min) later than the timestamp trade matching (time-stamp of trade provided by customer) Equity and equity-like only: All late publication warnings only apply from 9:00-17:45 If a transaction takes place outside of trading hours, then a warning is issued that the trade is published at or after 9:00 (beginning of trading) of the following trading day Exception processing Publication with warning In certain cases as e.g. used in chapter 7.2, a warning is returned to the customer, but the transaction is still published. The customer should double-check the transaction and may send a correction. Rejection with reject reason In case data in the report appears to be erroneous as used in chapter 4, the transaction is rejected with a message specifying the reason. The customer should double-check the provided data and correct erroneous fields to enable the publication. User Manual TTR II (V1.3) Page 25 / 56

26 5.4. Trade flags TTR II customers may refer to the separate Excel-specification All_Flags_APA_Overview for further details on the functional implications of trade flags in TTR II. Following MiFID II / MiFIR there are quite some trade flags to be used under different circumstances. In TTR II these are separated in non-functional flags (from TTR II perspective) as available in field MiFID2TradeFlags and functional flags, e.g. post-trade deferral flags. Both fields are available in the WebGUI accordingly, in the FIX interface several fields are available following the FIX standard. This chapter defines the allowed combinations of flags as published by ESMA Q&A On MiFID II and MiFIR transparency topics ESMA As a general approach, flags should only be applied in case the circumstances described in Table 1 apply. If none of the specified circumstances apply, the transaction should be published without a flag. Flag Name Description RTS 1 equity RTS 2 nonequity BENC Benchmark RTS 1: Transactions executed in reference to a price y y transaction flag that is calculated over multiple time instances according to a given benchmark, such as volume-weighted average price or time-weighted average price RTS 2: All kinds of volume weighted average price transactions and all other trades where the price is calculated over multiple time instances according to a given benchmark. ACTX Agency cross RTS 1+2: Transactions where an investment firm has y y transactions flag brought together customers price offers with the purchase and the sale conducted as one transaction and involving the same volume and price TNCP Transactions not Transactions not contributing to the price discovery y contributing to the process MiFIR Art 23 and as set out in RTS 1 Art 2 price discovery process (MiFIR Art 23) SDIV Special dividend Transactions that are either: y flag Executed during ex-dividend period where the dividend or other form of distribution accrues to the buyer instead of the seller (or vice versa in the cum-dividend period) LRGS Post-trade large RTS 1: Transactions that are large in scale compared y y in scale with normal market size for which deferred publication is transaction flag permitted under RTS 1 Art 14 RTS 2: Transactions executed under the post-trade User Manual TTR II (V1.3) Page 26 / 56

27 large in scale deferral. SIZE Transactions above the standard market size flag RTS 1: Transactions executed on a systematic internaliser where the size of the incoming price offer was above the standard market size RTS 1 Art 11 RTS 2: Transactions executed under the post-trade size specific to the instrument deferral. ILQD Illiquid instrument RTS 1: Transactions in illiquid instruments as transaction flag determined in accordance with Art 1-9 Commission Delegated Regulation executed on a systematic internaliser RTS 2: Transactions executed under the deferral for instruments for which there is not a liquid market. RPRI Transactions Transactions executed on a systematic internaliser with which have a price improvement MiFIR Art 15 (2) received price improvement flag TPAC Package Package transactions which are not exchange for transaction flag physicals as defined in RTS 2 Art 1 XFPH Exchange for Exchange for physicals as defined in RTS 2 Art 1 physical transaction flag CANC Cancellation flag RTS 1+2: When a previously published transaction is cancelled AMND Amendment flag RTS 1+2: When a previously published transaction is amended DUPL Duplicative trade When a transaction is reported to more than one APA in reports flag accordance with Art 17 (1) of Commission Delegated Regulation Table 1: MiFID II Trade Flags y y y y y y, but not published y y y y y y not required by RTS 2 but needed for SI calculations, will not be published CANC and AMND: The flags CANC and AMND apply in the same way for equity and non-equity instruments. The flags CANC and AMND should not be used when publishing all the details of a transaction after the lapse of the supplementary deferrals for non-equity instruments. User Manual TTR II (V1.3) Page 27 / 56

28 5.5. Deferred publishing = Waiver Concept In the TTR II waiver solution WBAG makes available all possible deferral waivers for post trade for equity & equity-like instruments (RTS 1) and for non-equity instruments (RTS 2). Pre-trade waivers in TTR II are supported for making public transactions according to any confirmation by NCAs, but are not checked for correctness nor have they any other functional implication within the TTR II system. Note these flags may only be entered in field MiFID II Trade Flag in the WebGUI or in according fields as described in the CEESEG FIX TTR II specification and published afterwards. Pre-trade waivers are not supported in TTR II. Pre-trade flags are not applicable to APA data or transactions are not to be flagged as such (see below an abstract from ESMA Q&A on Transparency Chapter 2, Answer 2a): Pre-trade waiver flags: RFPT, NLIQ, OILQ and PRIC [Regulated Market only]. Those flags should only be used in case of the effective use of the reference price waiver or the negotiated transaction waiver. Transactions benefitting from a LIS waiver are not flagged as such. Post-trade deferral waivers / their flags may be entered in field Post Trade Deferral Waiver in the WebGUI or in according fields as described in the CEESEG FIX TTR II specification. Non-functional flags, e.g. ACTX or BENC, may be entered in field MiFID II Trade Flag. The deferred publication of a record is achieved by setting a scheduled job in a scheduler to publish the record at the respective time. The publication is continued at the set time. The job data is stored in the database to ensure the functionality of deferred publication also in case of a short time outage of the application server. The timespan of the publication can t be influenced by the customer. It is preset by the MiFID II threshold table or defined by ana NCA. Should a trade be amended or cancelled during the deferral period, all transactions sent by the customer are published afterthe following procedure applies: If a trade is cancelled during the deferral period., no data is sent to ADH / published. If a trade is amended during the deferral period, only the amended trade is published. Following ESMA Q&A on MiFID II and MiFIR transparency topics (Chapter 8 Data reporting service providers), [ ] investment firms should report the transaction to the APA as soon as technically possible after the execution, regardless of the application of any deferrals. AnyAll waiver is set up by WBAG after transmission of the accordingare freely available within TTR II following FMA Handelstransparenzausnahmeverordnung No NCA confirmation. is necessary. Waivers are set up by WBAG, therefore a customer has to send the NCA confirmation for each waiver to be able to use it in the system. User Manual TTR II (V1.3) Page 28 / 56

29 Waiver processing: In general all trades are disseminated immediately. Deferrals are the exemption and are only possible if a waiver is set up correctly and in timeused by the customer. This means, within the GUI the waiver dropdown is only active with the approved waivers. In comparison, within FIX any sent deferral flags are compared to the waivers set up. In case the waiver applies, the publication is deferred following the rules defined below. If the waiver is not set up, the transaction is rejected. Processing during data input by customer via WebGUI: a. If no waiver is applicable, the transaction is published immediately. b. If a waiver is applicable, the system automatically activates the field Post Trade Deferral Waiver. This is aused via multi-select dropdown, where only the approved waivers for the ISIN are listed for selection. After selection of the deferral waivers, the system automatically defers the publication according to the rules below. Special note: i. The field Average Daily Turnover (ADT) is activated in case a LRGS = Large in Scale Waiver is selected. ii. The customer needs to insert the ADT mandatorily if it is not provided by the system with FIRDS data Deferrals for equity and equity-like instruments The only possible waiver for deferrals for equity or equity-like instruments is LIS-transaction (LRGS). LIS means Large in Scale. If a transaction with LRGS is sent via FIX or entered into the WebGUI, TTR II uses following fields inserted by the customer or automatically populated from FIRDS, to determine the deferral period applicable: Average Daily Turnover (ADT) not applicable if Instrument Type MiFIR = ETFS This field is automatically populated by FIRDS; if no value is available, it needs to be inserted by the customer mandatorily. The value needs to be inserted in EUR. Turnover This field needs to be inserted by the customer. The value needs to be inserted in EUR. The TTR II system determines the ADT class in the first column of the following tables (depending on the Instrument Type MiFIR) and then determines the deferral time based on the turnover of the transaction entered. for shares, depositary receipts, certificates and other similar financial instruments (SHRS, DPRS, CRFT, OTHR): ADT & turnover are processed for ETFs: only turnover is processed User Manual TTR II (V1.3) Page 29 / 56

30 Average daily turnover (ADT) in EUR > 100 m 50 m 100 m 25 m 50 m 5 m 25 m 1 m 5 m m < Minimum qualifying size of transaction for permitted delay in EUR Timing of publication after the transaction minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the trading day minutes minutes End of the next trading day Table 2: Deferred publication thresholds and delays for shares and depositary receipts (SHRS, DPRS) User Manual TTR II (V1.3) Page 30 / 56

31 Average daily turnover (ADT) in EUR ADT < ADT Minimum qualifying size of transaction for permitted delay in EUR Timing of publication after the transaction minutes End of the trading day minutes End of the trading day Table 3: Deferred publication thresholds and delays for certificates and other similar financial instruments (CRFT, OTHR) Minimum qualifying size of transaction for permitted delay in EUR Timing of publication after the transaction minutes End of the trading day Table 4: Deferred publication thresholds and delays for ETFs (ETFS) User Manual TTR II (V1.3) Page 31 / 56

32 Any LRGS trade with 60 min deferral executed o < 18:00 are published after 60 min o >= 18:00 are published at 07:30 on the following trading day 120 min deferral executed o < 17:00 will be published after 120 min o >= 17:00 will be published at 07:30 on the following trading day End-of-the-trading-day deferral that is executed o < 17:00 will be published at 19:00 >= 17:00 will be published at 12:00 on the following trading day Deferrals for non-equity instruments TTR II uses 2 calendars, one for working days, one for trading day (confirmation from FMA ): Arbeitstag ist izm Nachhandelstransparenz relevant (zb ART 11 von RTS 2; ein Arbeitstag an dem veröffentlicht wird, muss nicht unbedingt Handelstag sein) For the identification of working days and trading days 2 calendars should be used: - Working days are all weekdays where there is no public holiday in Austria. They shall be used for deferral calculations if mentioned accordingly / depending on the used deferral flag. - Trading days are all working days except Saturdays, Good Friday (Karfreitag), Dec 24 and 31. Publications are only possible on WBAG and/or partner exchange working days NOTE: Detailed deferral periods per flag can be changed (parametrization in Cockpit: per flag if FMA publishes standard deferrals and per waiver if FMA confirms individual deferral periods per confirmation ( Bescheid )), the values hereafter are to be seen as initial/default values. FMA may define different periods for all standard or supplemental deferrals (FMA on Sept 29, 2017: Vorab ist anzumerken, dass die FMA Ausnahmen zur Vorhandels- und Aufschub für Nachhandelstransparenz durch Verordnung gemäß 90 Abs 11 WAG 2018 gewähren kann. Die FMA wird davon Gebrauch machen und in einer neuen HandelstransparenzausnahmenVO (ähnlich wie bisher in der HTAusnV) entsprechende Ausnahmen und Aufschübe, nach jetzigem Stand auch für sog. Supplementary Deferral gemäß Art 11 Abs 3 MiFIR (und Art 8 bzw 11 RTS 2) vorsehen. Die Arbeiten daran werden in Q starten. Die VO wird selbstverständlich konsultiert werden.) Following standard deferral flags (= waivers) are possible: - LRGS (Large in Scale), - SIZE (Transactions above the standard market size), - ILQD (Illiquid instrument), - TPAC (Package transaction) and - XFPH (Exchange for physical transaction). User Manual TTR II (V1.3) Page 32 / 56

33 Transactions qualifying for the deferral waivers as mentioned above are made public on the second working day after the date of the transaction at 18:45 CET. In addition to that following supplementary flags / waivers are supported by TTR II, where a competent authority may grant deferred publication differing from the standard mentioned above:: Flag Name Description Supplementary deferral flags (RTS 2 only) LMTF Limited details flag First report with publication of limited details in accordance with Art 11(1) (a) (i) FULF Full details flag Transaction for which limited details have been previously published with Art. 11 (1) (a) (i) DATF Daily aggregated transaction flag Publication of daily aggregated transaction in accordance with Art 11 (1) (a) (ii) FULA Full details flag Individual transactions for which aggregated details have been previously published in accordance with Art 11 (1) (a) (ii) VOLO Volume omission flag Transactions for which limited details are published in accordance with Art 11 (1) (b) FULV Full details flag Transactions for which limited details have been previously published in accordance with Art 11 (1) (b) FWAF Four weeks aggregation flag Publication of aggregated transactions in accordance with Art 11(1) (c) FULJ Full details flag Individual transaction which have previously benefited from aggregated publication in accordance with Art. 11 (1) (c) IDAF Indefinite aggregation flag Transactions for which the publication of several transactions in aggregated form for an Transactions for which the publication of several transactions in aggregated form for an indefinite period of time has been allowed in accordance with Article 11(1)(d). VOLW Volume omission flag Transaction for which limited details are published in accordance with Article 11(1)(b) and for which the publication of several transactions in aggregated form for an indefinite period of time will be consecutively allowed in accordance with Article 11(2)(c). COAF Consecutive aggregation flag Transactions for which limited details have been previously published in accordance with Article 11(1)(b) and for which the publication of several transactions in aggregated form for an indefinite period of time has consecutively been allowed in accordance with Article 11(2)(c). User Manual TTR II (V1.3) Page 33 / 56

34 Table 5: Supplementary deferral flags (RTS 2 only) Cases, under which supplementary flags are relevant: There are two general implications of supplementary flags: Flags, which trigger the TTR II deferral (done within TTR II core) (hereinafter marked with TTR II deferral ) Flags, which do not trigger a deferral in TTR II; only the handling of data input checks is modified in these cases (as described accordingly below for each case). This is because the customer has to send full details for the final publication anyway. Case 1: Art 11 (1) (a) (i) In case a customer sends the LMTF flag, the customer has to publish all details but Volume immediately. In this case, no check on volume is done, as the field is empty. In case of the final publication with flag FULF, it is sent by client no later than 19:00 local time on the second working day after the date of the transaction. In case FULF the reporting delay check does not apply. Instead an additional check applies: check, if Trade_Date = t 2 working days and if the Reporting_Date_Time is <= 19:00. If FULF is sent later, a warning is issued. A warning message is sent as a reply to LMTF trade if FULF has not yet been sent after 19:00 local time on the second working day after the date of the transaction. NOTE: In case of LMTF or FULF no automatic deferral is done in TTR II Case 2: Art 11 (1) (a) (ii) In case a customer sends the DATF flag, the customer has to publish all details on the following working day before 9:00 local time (but volume) for at least 5 aggregated transactions with the same ISIN executed on the same trading day. Price field shall be empty, instead VolumeWeightedAverage shall be published (see Art 11 (4) below as well). In this case the reporting delay, volume and price check do not apply. Instead an additional check applies: check, if Trade_Date = t-1 and if the Reporting_Date_Time is < 9:00. If DATF is sent later, a warning is issued. In case of the final publication of individual transactions including volume the flag FULA is sent by no later than local time on the second working day after the date of the transaction.. In case FULA the reporting delay check does not apply. Instead an additional check applies: check, if Trade_Date = t 2 working days and if the Reporting_Date_Time is <= 19:00. If FULA is sent later, a warning is issued. A warning message is sent as a reply to DATF trade if FULA has not yet been sent after 19:00 local time on the second working day after the date of the transaction. NOTE: In case of DATF or FULA no automatic deferral is done in TTR II User Manual TTR II (V1.3) Page 34 / 56

35 Case 3: Art 11 (1) (b) + (2) (a) + (c) + (3) In case a customer sends the VOLO flag, the customer has to publish all details but Volume immediately. In this case, no check on volume is done, as the field is empty. The final publication including the volume and the flag FULV is made after 4 weeks have lapsed on the next working day before 9:00. In this case the reporting delay check does not apply. Instead an additional check applies: check, if Trade_Date = t- (4 weeks and 1 working day) and if Reporting_Date_Time is < 9:00. If FULV is sent later, a warning is issued. A warning message is sent as a reply to VOLO trade if FULV has not yet been sent after 4 weeks have lapsed on the next working day before 9:00 compared to the date of the transaction. NOTE: In case of VOLO or FULV no automatic deferral is done in TTR II In case the customer sends the VOLW flag, the customer has to publish all details for aggregated transactions but volume immediately. Price field shall be empty, instead VolumeWeightedAverage shall be published (see Art 11 (4) below as well). In this case, no check on price and volume is done, as the fields are empty. The final publication including volume incl. the flag COAF for aggregated transactions previously reported without volume has to be published after 4 weeks on the following Tuesday before 9:00. In this case the reporting delay and price check do not apply. Instead an additional check applies: check, if Trade_Date = t- 4 weeks on the following Tuesday and if Reporting_Date_Time is < 9:00. If COAF is sent later, a warning is issued. A warning message is sent as a reply to VOLW trade if COAF has not yet been sent after 4 weeks on the following Tuesday before 9:00 compared to the date of the transaction. NOTE: In case of VOLW or COAF no automatic deferral is done in TTR II Case 4: Art 11 (1) (c) In case the customer sends the FWAF flag, the customer has to send all details for all aggregated transactions per ISIN (no individual price but only VolumeWeightedAverage) within one calendar week. Publication is deferred one week to the following Tuesday at 8:45. In this case price and the reporting delay check do not apply. NOTE: FWAF triggers an automated deferral in TTR II In case 4 weeks have passed, a customer shall send individual transactions with the FULJ flag. In this case the reporting delay check does not apply. Instead an additional check applies: check, if Trade_Date = t- 4 weeks and if Reporting_Date_Time is < 9:00. If FULJ is sent later, a warning is issued. Other standard checks apply. A warning message is sent as a reply to FWAF trade if FULJ has not yet been sent after 4 weeks before 9:00 compared to the date of the transaction. NOTE: In case of FULJ no automatic deferral is done in TTR II User Manual TTR II (V1.3) Page 35 / 56

36 Case 5: Art 11 (1) (d) In case the customer sends the IDAF flag, the customer has to send all details for all aggregated transactions per ISIN (no individual price but only VolumeWeightedAverage) within one calendar week. Publication is deferred one week to the following Tuesday at 8:45. In this case price and the reporting delay check do not apply. See also Art 11 (4) below. NOTE: IDAF triggers an automated deferral in TTR II Individual transactions do not have to be published for an indefinitive period of time. Art 11 (4) The following is valid for all flags, which mark aggregated data (DATF (only regarding number of trades), FULA, VOLW (only regarding number of trades), COAF, FWAF, IDAF): For daily or weekly aggregated data the customer has to send the following details in respect to each day or week: Volume weighted Average Total traded volume in according measurement unit as described in the table 5 below Total number of transactions Measure of volume Type of instrument All bonds except ETCs and ETNs and structured finance products Volume Total nominal value of debt instruments traded ETCs and ETNs bond types Number of units traded (1) Securitised derivatives Number of units traded (1) Interest rate derivatives Notional amount of traded contracts Foreign Exchange Derivatives Equity derivatives Commodity derivatives Credit derivatives Contract for differences C10 derivatives Emission allowance derivatives Emission allowances (1) Price per unit Table 6: Measure of volume for non-equities Notional amount of traded contracts Notional amount of traded contracts Notional amount of traded contracts Notional amount of traded contracts Notional amount of traded contracts Notional amount of traded contracts Tons of Carbon Dioxide equivalent Tons of Carbon Dioxide equivalent In general, if the Tuesday of COAF, FWAF or IDAF is no working day, then publishing shall be done on the next working day at 8:45. User Manual TTR II (V1.3) Page 36 / 56

37 Full details to individual transactions shall be sent with the same TIC as the initial publication without volume is sent (except aggregation flags where no TIC is necessary with the initial publication). Aggregated transactions shall be sent by the customer as one consolidated technical transaction (no price but VolumeWeightedAverage). User Manual TTR II (V1.3) Page 37 / 56