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How should Exchange for Physicals ("EFP") transactions be reported to CAT?

How should Exchange for Physicals ("EFP") transactions be reported to CAT?

When an Exchange for Physical order has been received or originated, a New Order event must be reported with a handlingInstructions value of ‘EW’. If the transaction is affected through an ATS or other crossing system, an Order Route event must be reported by the sender, and an Order Accepted event must be reported by the receiver. If the order is executed via a direct negotiation with the counterparty, the Industry Member must follow the guidance outlined in the Industry Member Scenarios Document for reporting a negotiated trade. If an EFP transaction was originated in response to solicitation, the guidance outlined under B45 would apply.