Execution Timestamp Tolerance

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Status: For Review, Last Updated: 15/02/2023

Question:
Validation Field(s) in scope – 2.12

Counterparts to a transaction may, for legitimate business reason, generate different timestamps when reporting SFTs.

•Counterparties use booking times as a proxy for execution times may result in differences related to deal capture procedures. This leads to timestamp differences exceeding the current 1-hour tolerance.

•Where booking of a transaction is not automated, or where confirmation of transaction is delayed for various reasons, firms will generate individual booking times which may result in mismatching data.

•We note that actual booking times may provide extra insight to supervisory bodies reviewing SFTR data.

•Market participants concluded that the current one-hour tolerance causes unnecessary reconciliation breaks.

Best Practice:
ISLA members agree that increasing the currently mandated tolerance will reduce matching breaks and proportion of resource required to align those timestamps. Their proposal is therefore:

•To increase the timestamp tolerance to at three (3) or more hours which would significantly reduce reconciliation breaks while still providing regulators with useful insight into trading party practices.

•This proposal would not contradict the spirit of the regulation and would provide additional insight for supervisory bodies. (SFTR-452)