Execution Timestamp Tolerance

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Execution Timestamp Tolerance

Status: To Be Reviewed 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)