The aggregate client account (‘INTC’) should only be used in the circumstances set out in these Guidelines. It should not be used for reporting an order for one client executed in a single execution or for an order for one client executed in multiple executions. Where there is a transfer into the aggregate client account (‘INTC’) there should be a corresponding transfer out of the aggregate client account within the same business day of the executing entity in the transaction report such that the aggregate client account is flat. The apparent movement through ‘INTC’ is a convention used for reporting to provide a link between the market side and client side of transactions and does not indicate that such a client account exists in reality or that ownership of the instrument actually passes through the Investment Firm’s books.

 Article 11(2) of Commission Delegated Regulation (EU) 2017/590 provides that the short selling requirements under Regulation (EU) No 236/2012 apply where an Investment Firm aggregates orders from several clients. This means that Article 11(2) of Commission Delegated Regulation (EU) 2017/590 only applies to the reports showing the transactions with the individual clients rather than to an aggregated market transaction report. In the case of a market transaction report aggregating trades for selling clients, the short selling indicator should be blank. This is because the aggregated market transaction report relates to all clients whose orders have been aggregated and cannot specify the short shelling indicator at the necessary granularity. The short selling indicator for individual clients is instead reported in the individual client side transaction reports (see sections 5.24 and 5.27.2).

5.23.1 One market fill for several clients