“Third Country Organized Trading Platform”, this is a key point Knowing whether the trade was made on a “Third Country Organized Trading Platform” is one of the key points of EMIR REFIT reporting, because it has an impact on several fields, starting from field 3, "Entity Responsible for reporting", 2.29 "Confirmed", 2.30 "Cleared obligation", 2.37 "Intragroup", to the most famous one, field 2.8, the UPI ! As of today, there is no clear answer, even from the Trade Repository. The reason is that ESMA provided a mapping file which was not precise enough, as based on the Exchange common name rather than its MIC Code (https://www.esma.europa.eu/sites/default/files/library/equivalent_tc-markets_under_emir.pdf). From our standpoint, the “Third Country Organized Trading Platform” notion is to avoid having to populate these fields and in particular the UPI for non-isinized ETDs (especially on american markets). But we are waiting for confirmation of our interpretation from ESMA. Did you come across the same issue? #EMIRRefit #EMIR #REFIT #TransactionReporting #RegulatoryReporting #RegulatoryCompliance #Regtech #PortfolioCode #UTI #UPI