MiFID II introduces very specific requirements regarding post-trade information and when to publish the information for non-equity instruments.
This implies significant changes to the current post-trade information available in Genium INET and GCF. The trade ticker will be changed to include a few new data fields and new flags.
Deferral of Publication
Currently publication of trades large in scale may be deferred until End-of-Day (EoD) at the latest.
MiFID II specifies that the National Competent Authorities (NCAs) may authorize a deferral of the publication until 19:00 on day T+2. This goes for trades large in scale or for trades in illiquid instruments.
NCAs have even the possibility to authorize a deferral of up to four weeks.
MiFID II then introduces a very complex regime of deferrals – as the individual NCAs may implement different deferral models in their home markets.
Nasdaq plans to implement the Nordic deferral models (i.e. deferral models authorized by the Nordic NCAs) and to be able to administer deferrals on all Nordic listed instruments.
Trade Cancellations and Amendments
Currently Genium INET only handles cancellations and amendments intraday, i.e. cancellations must be completed before closing of the markets.
Nasdaq plans to add the option of cancellation and amendments of “historic” trades – however only for trades not yet settled, i.e. cancellation must take place before the specified settlement date.
The cancellation message will also be changed. MiFID II requires that all original trade information shall be included in the cancellation message and that a cancellation-flag be added.
Amendments require a cancellation message and a new trade message that includes of all the original information, the amended information, and an amendment-flag.
Changes in Reference Data
In order for Nasdaq to comply with the above mentioned pre- and post-trade transparency requirements, some new reference data needs to be registered and some existing reference data may need a change in format.
Nasdaq intends to incorporate all relevant new reference data in the appropriate messages and in the Genium Consolidated Feed (GCF).