Trading with Confidence for all UK based Clients

Taker side – no brokerage charged
Maker side – Schedule of Fees (valid from 9 January 2024) – 360T UK MTF (PDF)

Waiver

Foreign Exchange (FX) is currently generically classified as being a non-liquid financial instrument. In adherence to the waiver we sought from the FCA regarding pre-trade transparency obligations, 360T UK MTF will not make public the current bid and/or offer prices or the depth of trading interests at those prices.

Given that 360T UK MTF is based on a Request for Quote trading model, it is believed that providing such transparency would not be in the interests of MTF market participants or the wider FX market.

360T UK will of course continue to evaluate the benefit of maintaining the pre-trade transparency waiver and to ensure that its MTF operations remain fully compliant with both the obligations and the spirit of MIFIR.

360T UK will provide post-trade transparency information about Transactions executed through the 360T UK MTF, subject to any rights to defer or limit publication.

1. MTF Activation

Why do I, as a 360T admin user, have to enter Personally Identifiable Information (PII) of my firm’s users into your system before we can trade on 360T’s UK MTF?
As an authorized and regulated operator of an MTF by the FCA, 360 Trading Networks UK Limited (360T UK) must fulfill “transaction reporting” and “record keeping” obligations in accordance with MiFID II. These reports must include the PII data requested.

Which PII information must 360T collect for the UK MTF?
A natural person must be identified in a transaction report by using a National Client Identifier specified in Annex II of the relevant Regulatory Technical Standards based on the nationality of the person. 360T UK must collect the “Nationality” and “National Client Identifiers” of UK MTF users. The National Client Identifiers to be entered depend on the Nationality of the users.

Which National Client Identifiers should I enter if the system allows me to enter more than one identifier?
The National Client Identifier must be reported in accordance with the priority levels provided in Annex II using the highest priority identifier. For the UK MTF, the 1st priority National Client Identifier must be entered. If the given user is not in possession of this identifier, the second must be entered etc. You should always aim to provide the 1st priority identifier.

As an admin user, I should not be able to see the PII data of my firm’s users once entered. Does 360T offer a feature to obfuscate the PII after being entered?
Yes, 360T offers a “sensitive mode” feature which can be activated by 360T’s Client Advisory Services (CAS) team.

Are there differences between the PII data that are collected for the EU MTF and UK MTF?
The National Client Identifiers are different for the nationalities “UK” and “Liechtenstein”, refer to the table below:

Otherwise, they are consistent.

We traded on the EU MTF previously and need to migrate to the UK MTF. Which options does 360T offer to copy PII data from EU MTF to UK MTF?
It is possible to download the PII data of the EU MTF as a csv file. Then, the PII data for users with the nationality UK or Liechtenstein must be adjusted in the csv before being uploaded into 360T’s system for the UK MTF. However, this feature is not possible in “sensitive mode”.

What are the possible values for Trading Capacity? And how are they used?
DEAL: Trading on own account
MTCH (Matched Principal): a transaction where three conditions must be met:
– The facilitator interposes between buyer and seller to the transaction in such a way that it is never exposed to market risk
– Both sides are executed simultaneously (timing)
– The transaction is executed at a price where the facilitator makes no profit or loss, other than a previously disclosed commission, fee or charge of the transaction.
AOTC (Any other Trading Capacity): AOTC must be selected if DEAL or MTCH is not applicable

Do I have to select an Investment Decision Maker?
The Investment Decision Maker should only be entered when the Trading Capacity “Deal” is used. Otherwise, this field can be left blank as PII data would need to be collected from your customers, which is not the intention of the regulators.

2 Reporting

What is the Legal Entity Identifier (LEI) of “360 Trading Networks UK Limited”?
The LEI is 529900MXX9KHFAUADV11

What is the MIC code of 360T’s UK MTF?
The MIC code is “G360”.

What is the format of the TVTICs generated by 360T’s UK MTF?
The format of the TVTIC (Trading venue transaction identification code) consists of a prefix and a trade id. The prefix holds the LEI “529900MXX9KHFAUADV11”.

When does 360 Trading Networks UK Limited report transactions to the FCA?
In accordance with MiFIR, Article 26(5), 360T UK shall submit a transaction report for a transaction executed on UK MTF to the FCA when a trade counterpart is not a UK-regulated Investment Firm/Credit Institution.

In terms of Swaps, does 360T distribute ISINs on a Swap level or leg level?
Swaps are defined as falling into two categories, a single FX Swap instrument and a FX Strategy (or FX Strat as it may be called). A FX Swap will be reportable as a single instrument with a single ISIN. A FX Strategy will be reportable as a two-legged instrument with ISIN’s for each leg. 360T facilitates trading of FX Strategies. FX Swaps, reportable as a single instrument with a single ISIN, are currently not supported.

Will 360T carry out APA reporting?
If a trade is concluded on 360T’s UK MTF then 360T has a post-trade transaction reporting obligation to fulfill. However, MTF trades are not published via an APA but made public through other means.

3 Data Protection

How does 360T secure PII data?
Individual confidential data, including Nationality and National Client ID will be recorded and maintained within the 360T datacenters in an encrypted format. Data necessary for MIFID Transaction Reporting purposes, including PII, will be processed in accordance with the applicable regulatory guidelines. The responsibility lies with the MTF participant to ensure that all data entered in the configuration tool is valid.

How long will personal data be retained?
360T is cognisant of the requirements under the General Data Protection Regulation (GDPR) and other legal requirements. Data is retained only for the period required. As this data is primarily retained to comply with regulatory requirements, data is deleted after the expiry of the obligation to retain data for audit and regulatory purposes.

4 Interfaces

As a Liquidity Provider, can we use the same Algo Ids for UK MTF which we are using for EU MTF?
Yes

We are using the RFS Market Maker API (or RFS Market Taker API). What are the differences in the API messages between UK MTF and EU MTF?
The differences are as follows:

We traded only on OTC bilateral basis so far. Which MTF enrichment fields will we receive as part of the transaction details via our interface when trading on the UK MTF?
In general, we distribute following MTF enrichment fields when a trade occurs on the MTF:

• Trading Venue = MTF
• ISIN (International Security Identification Number)
• CFI (Classification of Financial Instruments)
• MIC (Market Identifier Code)
• TVTIC (Trading Venue Transaction Identification Code)
• LEI (Legal Entity Identifier)
• Trading Capacity
• EDM (Execution Decision Maker)
• IDM (Investment Decision Maker)
• Pre-trade transparency waiver
• Post-trade deferral
• Transaction time in msec
• Frame id for each transaction being part of a block negotiation.

It depends on the interface used whether the above-mentioned fields are sent across or not.

We are using a Taker API to fully automate our trading workflow. So far, we traded only on OTC bilateral basis via 360T. Do we have to adjust our interface to trade on UK MTF?
If the automated workflow foresees no manual intervention by the trader within 360T then the interface must be adjusted with following information:

• Trading Venue = UK MTF
• EDM (Execution Decision Maker)
• IDM (Investment Decision Maker)
• Trading Capacity