Backloading / Trade ID

Is an agreed Trade ID also necessary for backloaded trades?

ESMA's answer to this question (Q&A document as of June 4, 2013): To the extent that a backloaded contract is still outstanding at the time of reporting, a Trade ID needs to be agreed between the two counterparties and reported, together with the other information on that contract.

This means that for all other trades that have expired before the start of the reporting obligation it is neither necessary to 'invent' a Trade ID (e.g. for internal trades) nor to check with the respective banks. Trade IDs will have to be reported (and generated for internal trades) only for trades that still exist on the start date of the reporting obligation.

Regarding the generation of Trade IDs for internal trades, we recommend using the LEI/GEI together with e.g. the company name and a serial number - this should be sufficient in order to generate a EU-wide unique Trade ID.