5. Decisions in your firm
The FCA wants to know who in your firm was behind each trade. There are two separate questions.
Who decided to invest? (investment_decision_id)
Fill this in when your firm made the investment decision:
- when you deal on your own account; or
- when you manage a client's money with discretion.
Give the person who decided (their personal identifier, like a client's), or the algorithm code if an algorithm decided (type ALGO).
Leave it blank when the client decided an order you handled in an AOTC or MTCH capacity, for example an execution-only order. Every DEAL trade needs it, including an execution-only order for a client that you fill as principal.
Who executed it? (execution_decision_id)
The person or algorithm in your firm mainly responsible for executing the trade: usually the dealer who placed it, or your order-routing system. For a person, give their national identifier and the matching type. For automated execution, give the system's code with type ALGO.
If no one in your firm was responsible (for example the client executed it themselves), leave it blank and we report NORE on your behalf.
Direct electronic access (DEAU)
If your firm gives a client direct electronic access to a venue through your membership, and the client decides how the order is executed, use type DEAU. Until the new rules take effect on 3 April 2028 the FCA has no such code, so we report these as NORE for you. If you don't offer direct electronic access, you won't need it.
Algorithms
If you use algorithms, give each one a stable code of your own (for example ALGO1) and keep a record of what each code means, as the FCA can ask for it.
Keep personal identifiers up to date
The people in these fields are your staff. Hold their national identifiers as you would a client's, and keep them current when people join or leave.
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