|Transaction Reference Number (TRN)|
|European Union Electricity Market Glossary|
The Transaction Reference Number (TRN) is used under MiFID I by the reporting entity to cancel or amend transaction reports (field n°22 of table 1 in annex 1 of Implementing Regulation 1287/2006).
It is also used by competent authorities when requesting additional information related to the transaction report under MiFID reporting scheme. It is required to be consistent and persistent only at the level of a reporting entity, no matching being required with other entities.
Under the MiFID II the Transaction Reference Numbers will be retained and amended to comply with the following rules:
i. It uniquely identifies every transaction report sent to the competent authorities at the investment firm level;
ii. It is a unique, persistent and consistent code at the level of the investment firm; and
iii. In the particular case of a transaction report pertaining to direct execution on a trading venue, it shall be the same as generated and disseminated by the trading venue to both the buying and the selling parties when confirming the execution.
This is reflected in the ESMA's Consultation Paper Guidelines on transaction reporting, reference data, order record keeping & clock synchronisation 23 December 2015 (ESMA/2015/1909), which prescribes the required population of respective fields of MiFID II transaction reports as follows:
"Transaction reference numbers shall be unique to the executing firm for each transaction report and shall not be re-used even where the original transaction report is cancelled, except where the original transaction report is being corrected in which case the same transaction reference number shall be used for the replacement report as for the original report that it is being amended" (p. 69).
Pursuant to the draft Regulatory Technical Standard (RTS 22: Draft regulatory technical standards on reporting obligations under Article 26 of MiFIR) attached to the said ESMA's Consultation Paper of 23 December 2015, the designation of the Transaction Reference Number is envisioned in the Field No 2 of the Table 2 (Details to be reported in transaction reports) with the following description of this item:
"Identification number that is unique to the executing firm for each transaction report .
TRN has been initially decided to be also used under EMIR for EMIR reporting purposes, but in the Consultation Document, Review of the technical standards on reporting under Article 9 of EMIR of 10 November 2014 (ESMA/2014/1352 ESMA said:
"The current Table 2 Field 9 "Transaction Reference Numbers" was intended to mirror the equivalent field in a transaction report created according to Article 25 MiFID. As this logic has been amended further to ESMA clarification of ETDs reporting, it now conflicts with the concept of Transaction Reference Number within MiFID transaction reporting. For the avoidance of confusion and in order to better reflect the purpose of this field, it is proposed to rename the field to "Report Tracking Number" while maintaining its population logic, i.e. unique code assigned to the execution and common among a group of reports related to the same execution."
The idea to replace Transaction Reference Numbers in EMIR reports with Report Tracking Numbers was upheld in the ESMA's Final Report Review of the Regulatory and Implementing Technical Standards on reporting under Article 9 of EMIR of 13 November 2015 (ESMA/2015/1645), p.11, and finally implemented in the Commission Implementing Regulation (EU) 2017/105 of 19 October 2016 amending Implementing Regulation (EU) No 1247/2012 laying down implementing technical standards with regard to the format and frequency of trade reports to trade repositories according to Regulation (EU) No 648/2012 of the European Parliament and of the Council on OTC derivatives, central counterparties and trade repositories.
|Last Updated on Wednesday, 15 February 2017 02:51|