TRS FAQs

The FSA's Transaction Reporting System (TRS), live since November 2005, is a web based approved reporting mechanism (ARM) that enables firms to submit data to the FSA for the purpose of Regulatory Reporting under SUP17. TRS allows firms to report using three methods:

• Manual keying
• Web-upload
• System to System Transfer

For Web-upload and System to System Transfer,TRS uses XML as a basis for firms reporting their data. For more information on XML please refer towww.w3.org/XML/. TRS also allows firms submitting low volumes to manually key in this data. To learn more about how to use TRS please launch the Computer Based Training (CBT) package available via the TRS launch page at https://trs.fsa.gov.uk/.

TRS is required to comply with the transaction reporting provisions of the European Markets in Financial Instruments Directive (MiFID) which came into effect on November 5, 2007 (Chapter 17 of the FSA Handbook Supervision Manual).

In particular, MiFID required TRS to apply to become an Approved Reporting Mechanism (ARM). Pursuant to MiFID, transactions can be reported to the FSA by a regulated market or multi-lateral trading facilities (MTF) through whose systems the transactions were completed, or through an ARM. On October 3, 2007, TRS was granted approval as an ARM in the United Kingdom after complying with the FSA's technical specification (for further information on ARMs please see the ARMs section of our website).

Changes were made to TRS in line with the FSA's technical specification and supporting documents. These allow firms to report to us in line with SUP17, please see FSA Policy Statement 07/2).

Along with the XML schemas, we have produced a Data Reference Guide to help firms intending to submit transaction reports using 'system to system' data transfer or by 'web upload'.

The Guide outlines the XML format and data field requirements and explains in further detail the XML schemas used for submitting transaction reports to us. The Guide will be useful to IT professionals and others with an understanding of XML.

This document describes the data transmitted as Validation Replies from our Transaction Reporting System (TRS) to the firm's own systems for those firms reporting via 'system to system'.

To register for access to TRS, please call the TRS Service Desk on 0870 0130467, quoting your FSA reference number. Each firm that registers for TRS will need to identify a member of staff who will be the Primary Contact between the TRS Service Desk and the registered firm for all matters relating to TRS. Once you have registered, to access TRS please enter the following URL in to your web browser: https://trs.fsa.gov.uk/.

There are two basic methods to input transaction data: (a) keying the data in via Web Forms or (b) creating an off-line XML file. The use of the off-line XML method itself has two different processes: (1) Web upload (HTTPS) or (2) System to System (SFTP). The XML files used in both of these approaches are identical in structure, only the method of transfer differs.

Under this method, you enter transactional data into data fields accessed online. As you enter each transaction, the fields are validated and any validation errors are displayed immediately. This method of manual data input is best suited to firms:

• with lower volumes of data or without any integrated back-office system;
• that typically use a dial-up method of communication;
• that do not have a dedicated IT resource or computer support person available in their organisation.

There are several ways an XML file containing transactional data may be created. Users may have (a) an existing back-office system that has been modified to produce the XML file, (b) procured a new system to produce the XML file or (c) identified a method of ‘manually’ creating an XML file from current system data, by exporting from MS-Excel for example.

Having created an XML file, you have to decide whether to use Web Upload or System to System (SFTP) to transmit this XML file to the FSA. You do not need to do this purely because of volumes; you may decide to use one approach because it is more convenient.

6b(1). Web Upload

For this, you generate an XML file outside of TRS and then use TRS to upload the file. Through the web browser, you can access the TRS XML upload screen and the browse facility. This browse facility is used to navigate to the appropriate path to identify the file to be uploaded. Once you have submitted the file, TRS will validate it and, once the validation process has finished, will provide feedback while you are still online. (This approach is often described as ‘synchronous’). For users of Internet Explorer, within the browser window, the status bar will show the progress of the upload, and in all browsers a series of dots displayed will show that the validation process is active.

Web Upload can be used to manually send any XML file. However, there is a file size threshold (35MB) at which point the Web Upload becomes too slow. For guidance, in file transmission terms, a dial-up modem is very slow whilst broadband or fibre-optic connections can be very fast.

For these reasons, this type of input could be considered by firms:

• with only moderate volumes of data, with some form of back-office system or package that generates an XML file;
• with some form of medium speed communication such as broadband;
• that probably have a basic IT awareness or limited access to a dedicated IT resource available in their organisation.

6b(2). System to System (SFTP)

This also involves generating an XML file outside of the TRS application, but it uses an external method of file upload and download of the validation results using Secure File Transfer Protocol (SFTP). Each of these steps are distinct phases – the upload of data and the download of results are separate SFTP sessions. Between these sessions, firms must allow sufficient time for the file to be validated and parsed. (This approach is very often described as 'asynchronous'). See the other questions covering the detail of the SFTP process and downloading validation results.

The advantage of the System to System (SFTP) approach is that the data transfer can be initiated by a form of automated script that can be scheduled to run at the appropriate time. For example it could be that an XML file of transactions is assumed to have been captured in a known location at a specific point in time ready for the 'automation' script to be enabled to transfer this file to the FSA. This method would not be size constrained, as it could be used to transmit any size file.

The System to System (SFTP) approach tends to be more efficient as it compresses the data to make the size of the data file to be transmitted as small as possible and therefore, decreases the file transfer time. Therefore, this method could be considered by firms:

• with large volumes of data generally with some form of back-office system;
• with either a medium/high speed communication such as broadband or fibre optic connection;
• that probably have a dedicated IT resource available in their organisation.

The FSA positively encourage you to verify the validity of your XML file by running the file through an XML parser. This will avoid unnecessary delays in uploading XML files that may contain errors that need to be resolved and ultimately reduce the amount of future effort in resolving data errors.

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Before you are allowed to submit transaction reports using the web upload or system to system methods, you must conduct testing in the TRS Trial Application (by submitting a file with at least 10 transaction reports) and confirm your ability to submit a correctly formed XML using the Markets Data Schema (version 1-1). When you are ready to apply for certification, contact TRS Service Desk on 0870 0130467, quoting your FSA reference number, and let them know that you have submitted transaction reports which require checking for certification purposes. The TRS Service Desk will then review those reports and advise whether you have successfully certified. Once certified, you will be allowed to use the main XML upload facility and you will be provided with the full SFTP user details.

We will try to support as many browsers as possible; however, it must be appreciated that we are unable to support all web browsers either currently available, or that have since been superseded by more up-to-date versions.

Please note that for ease of use the TRS screens have been developed with a 1024 x 768 screen resolution.

All data transmitted, regardless of approach, will use a ‘secure’ method of transfer. Web input and Web Upload will use HTTPS and System to System will use SFTP (as opposed to HTTP and FTP; the ‘S’ indicating a secure connection). These secure methods of transfer use encryption processes before sending the data and appropriate decryption processes at the receiving end. Therefore, the communication channel performs the encryption and not any proprietary vendor software outside of TRS.

Technical reference and protocol information: HTTPS: www.w3.org/Protocols/
SFTP: www.w3.org/Protocols/rfc959/
also www.faqs.org

If you are planning to use an XML method of data input, you should download both the XML Schemas and a copy of an XML parser / validation process, so your files can be validated off-line before uploading to the FSA. For System to System, you will also need to acquire a copy of a Secure File Transfer Protocol (SFTP) client.

If you are planning to use the Web input method of data input, you do not need to do anything further at this time.

When you register, the TRS Helpdesk will ask you to confirm which method(s) you will be using and provide you with the relevant access details. To register, please call the TRS Helpdesk on 0870 0130467, quoting your FSA reference number.

You will need a Secure File Transfer Protocol (SFTP) client, software that is generally available in two forms. One version uses a Windows interface, whereby the screen is typically (although not always) divided into two windows, and files are transferred between you and the FSA by dragging files with a mouse. The other version uses some form of command level interface, by which a call to STFP may be performed as a script. We cannot recommend a particular package, but the following links describe some of the free versions of this software:

www.thefreecountry.com/webmaster/freeftpclients.shtml, or

www.uk.openbsd.org/openssh/windows.html

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We will provide you with a userID and password for the SFTP server when you register and certify for TRS.

The following is an example of an SFTP upload script:

1. OPEN trs.fsa.gov.uk
2. 15782
3. Abc123
4. CD report_upload
5. LCD trs_transmit
6. PUT filename.xml
7. QUIT

For more information see the System to System Interface Guide.

The System to System method of data transfer does involve a physical disconnect between the two stages (i.e. XML upload and the Validation report download). Therefore, following transfer and disconnection, there is a requirement to reconnect to download data validation and data transfer results.

This information in the form of a validation results XML file will be produced detailing the results of the XML upload and any errors identified. This file will be available for download and local processing once the validation process has been completed. Please refer to the Validation Replies Schema and the Validation Replies Data Reference Guide for more information.

Web Upload results will be reported back automatically online once the upload and validation have been completed and been processed. If you use the System to System method you can either query the data transfer results or view the results in the report summary screen online. There is no alert mechanism to inform the sender that a file has completed verification. So you should leave 30 minutes after uploading, when using the System to System interface, before you request a subsequent download of the validation results or view the results online.

You can pass your XML file to a local validation process before committing this file to the FTP server. To complete this exercise, you should download the appropriate FSA XML Schemas, and also a copy of an XML parser / validator and use the XML schema to validate an appropriate XML file.

Please contact the TRS Service Desk on 0870 0130467 or via email at fsa.uk@logica.com, quoting your FSA reference number, to request the TRS Markets Schemas. The TRS Helpdesk with then email them directly to you. Please note, you must be registered with TRS in order to obtain the Schemas.

Every XML Report file that is sent to the FSA must be validated against the relevant TRS XML Schema available on our website. So it is necessary for firms to acquire appropriate software. We cannot recommend a particular software package, but the following link lists some of the more well-known versions:

www.garshol.priv.no/download/xmltools/cat_ix.html#SC_XMLVal

The use of XML can increase the size of the file being transmitted – by 8 to 15 times the actual data content. This will affect the time the transmission takes, along with other environmental factors such as the size and type of communications link used.

The following is an example of an SFTP validation script:

1. OPEN trs.fsa.gov.uk
2. 15782
3. Abc123
4. CD results_download
5. LCD trs_results
6. GET filename_rpt.xml
7. QUIT

For more information see the System to System Interface Guide.

TRS is managed by LogicaCMG on behalf of the FSA. Please email the TRS Service Desk on fsa.uk@logica.com.

To help familiarise firms with TRS, and in particular to aid the Certification process, a Trial facility is available to firms once they have been through the Registration process. When you register we will give you access to the TRS Trial Application. Users wanting to submit data using XML will have to confirm their ability to generate a correctly formed XML file before they will be considered ‘Certified’, and are then able to fully utilise the system. To register for access to TRS, please call the TRS Service Desk on 0870 0130467 quoting your FSA reference number.

The Primary Contact can set up TRS users and re-set their passwords. We recommend Primary Contacts give at least one other TRS user the role of Administrator so they can set up users and re-set passwords if the Primary Contact is not available.

You will need to identify a member of staff who will be the Primary Contact between the TRS Service Desk and the registered firm for all matters related to TRS. Your TRS Primary Contact will receive notifications of any technical changes etc related to TRS. Your new Primary Contact will need to call the TRS Service Desk on 0870 0130 467.

Yes, you can. You just need to contact TRS Service Desk on 0870 0130 467 and ask them to link your FRN with the FRN of the reporting firm. For more information please see TRS Markets Data Reference Guide version 4-0.

The transaction reports you submit through any of the Approved Reporting Mechanism (ARM) go through a second level of validation carried out by the FSA.

This means that even if your transaction report has been accepted by the Transaction Reporting System (TRS) it might still be rejected by the FSA. Currently, firms who have submitted such reports are not automatically informed of these rejections.

The ‘FSA Rejection Process’ will therefore allow FSA’s rejections to be passed back to the submitting firms. An email will be sent to the primary contact of the firm and the users that submitted the files containing errors to notify them of their FSA rejections

At the close of each business day TRS will generate an email to firms whose transaction reports have been rejected by the FSA, irrespective of the submission method (manual keying, web upload and system to system). The email will be sent to the primary contact of the firm and the users that created the reports containing the rejected transactions. There will be one email generated per firm per day (assuming that there have been FSA rejections).

The email will tell you the report name that your firm submitted which included the rejected transaction, but will not contain details of the errors themselves.

To see the errors, please log on to TRS and go to the ‘View Submitted Reports’ section. You’ll see a column headed ‘FSA Rejections’ on the ‘Submitted Reports’ screen displaying the number of errors. You can then click on the number which will take you to the appropriate FSA rejection screen. If you are submitting via the System to System functionality, you can log-in as normal to the Secure File Transfer Protocol (sFTP) to collect the XML response files as you currently do now.

The Computer Base Training Application on the TRS website will be amended to cover these changes in relation to the new rejections procedure.

If your firm hasn’t received an email at the end of the day this might mean two things:

• First, the FSA did not detect any errors in the file submitted on this day.
• Second, your file is still being processed by the FSA. In this case, the message ‘FSA processing in progress’ will appear under the column ‘FSA Rejections’ on the ‘Submitted Reports’ screen. Once, the FSA has finished processing the file the number of errors will appear under the ‘FSA Rejections’ column and an email will be sent if any errors have been detected.

If you receive any rejection(s), please arrange for someone in your firm to correct the transactions and re-submit them.

We recommend that you re-submit or cancel any erroneous transaction reports as soon as possible to ensure the FSA has accurate information and a complete view of the market for monitoring purposes.