Block Trade Reporting - Do you do adequate training? The exchanges are watching.

Block trade reporting is a simple exchange rule requirement. The technical aspects vary slightly between exchanges but there are three basic things you need your staff to now:
1. Are you doing a bilateral trade that needs to be reported or is there a broker responsible?
2. If you are reporting, do you know the reporting path and the time period in which you need to report?
3. Do you know what data has to be reported and is there a party in your firm responsible for the report?

The CME just fined ICAP $1k for failing to report three trades on time. The notice is here - https://www.cmegroup.com/notices/disciplinary/2018/08/cme-rsrh-18-5143-icap-corporates-llc.html#pageNumber=1. The fact that the violations were only 4 months ago lets you know how closely they follow this.

The fine is only something like a corporate speeding ticket but it also serves as an indicator to an exchange that your staff may not be properly trained and compliance may not be rigorously supervising activities. It is better to make sure that you have training and operational materials covered.

DCM provides training and guidance materials for interested clients - just ask us.