Both the DEA provider and the DEA client, if it is an Investment Firm, should submit a transaction report (subject to the exception mentioned in variant B).

 When transaction reporting, the DEA provider should ensure to identify itself as the executing entity (Field 4 Executing entity identification code). Since the DEA user (the client) is making the decision on how to execute the DEA provider should populate the execution within the firm field with ‘NORE’ as set out in 5.12. The DEA provider should never fill in Field 57 (Investment decision within firm) as it is never involved in the investment decision which is the DEA client’s responsibility. Moreover, the DEA provider should report as acting in AOTC or MTCH capacity (Field 29).

 In its transaction report, the DEA client should identify the DEA provider rather than the market as either the buyer (Field 7 - Buyer identification code) or the seller (Field 16 - Seller identification code) as applicable. Moreover, it should always populate Field 36 (Venue) as ‘XOFF’ as it is not the entity facing the market. However, it is highlighted that where the DEA client is acting on behalf of a client and where it has transmitted the details of that client pursuant to the conditions provided under Article 4 of Commission Delegated Regulation (EU) 2017/590, the DEA client should not transaction report as all the relevant transaction information will be provided to the competent authority by means of the DEA provider’s transaction report.

5.28.1 Scenario 1: the DEA client is dealing on own account with no underlying client

Example 80