The Client identification code (Field 3) is used to identify the client of the member or participant. Only the LEI or {NATIONAL_ID}, as the case may be, of the immediate client of the member or participant of the Trading Venue should be populated in Field 3. The obligation to maintain the Client identification code (Field 3) neither requires Trading Venues to record the client ID of the end client nor any other client ID of intermediaries in the chain from the immediate client of the member or participant to the end client. The below flow chart illustrates the above explanation: the client of the Trading Venue’s Member or Participant is Investment Firm 1.
Operators of Trading Venues should request the client identifier of the immediate client from its member or participant and populate Field 3 with that client ID.
In the event the client ID is not collected at the time the order is submitted to the Trading Venue operator, the operator should obtain the missing client ID as soo
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