Block Trades – Reporting and Recordkeeping

Block Trade Reporting

After a block trade is consummated, it must be submitted to the exchange via CME Direct or CME ClearPort within 5 or 15 minutes, depending on the product. Specific reporting times are set forth in the Market Regulation Advisory Notice on block trades.

This may be done by each of the counterparties to the trade or through the broker. Once submitted, provided that the trade terms match, the price report of the block trade will be disseminated to the marketplace and appropriate clearing functions will be completed.

The time of execution of a block trade is the time that the parties agree to the trade. You must accurately report the time of execution of the block trade when submitting it through CME Direct or CME ClearPort. Reporting inaccurate execution times may result in disciplinary action.

Where it is necessary for parties to agree to the individual leg prices on certain spread and combination trades to submit the trade, parties must do so as expeditiously as possible after agreeing to engage in the block trade.

Single-Sided Entry

For single-sided entry, the buyer and seller of a block trade may agree to separately enter their side of the block trade into CME Direct or CME ClearPort, indicating each other as the opposite party. In this circumstance, both the buyer and seller must enter their respective side of the transaction within the required time-period.

Or one side of a trade (either the buyer or seller) may agree to enter their respective side of the trade and allege that trade against the other party. In this circumstance, the other party must ensure the alleged trade is accepted (complete with the correct account information for their side) within the required time-period. Consequently, the first party entering their side of the trade should ensure the information being entered is correct and must leave enough time for the second party to accept the trade within the requisite time-period.

Dual-Sided Entry

For dual-sided entry where a broker or other representative is entering the buy- and sell-side of the block trade on behalf of the counterparties, the broker or other representative is responsible for the entry of the block trade within the requisite time-period.

Block trades negotiated immediately prior to or during times when CME ClearPort or CME Direct are closed must be submitted no later than 5 or 15 minutes after the time CME Direct or CME ClearPort reopens, depending on the reporting requirement for the specific product.

Record Keeping for Block Trades

Complete order records for block trades must be created and maintained pursuant to Rule 536 and CFTC Regulations. Additionally, the time of execution of the block trade must also be recorded for all block trades.

This is part of a course on block trades. For official regulatory guidance on block trades, reference the applicable Market Regulation Advisory Notice.

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