Question 3.1.18

Reference to documents: TRUM – Table 2 Reporting

We can trade transactions which will be reportable under Table 2, for which a premium or fee is payable at inception, regardless of the delivery or flow of the underlying commodity, however the deal is not considered an option.

We are therefore unsure as to where to report the deal premium or fee. If the trade was an option, it would be reported under Field 15, but this could already be populated with the pricing formula of the trade.

As per example 9.01 in Annex II of the TRUM which is an annual gas swing contract. If a fee or premium was payable for that contract on transaction date, regardless of the final delivery flow, where in Table 2 would that premium be recorded?

An obvious place would be Field 15, but this has already been populated with the pricing formula for transaction.

A possible solution would be to describe the formula in Field 15 and then add the premium as an absolute amount at the end of the formula. Would this be acceptable to ACER?

Answer

When a transaction reportable under Table 2 includes a premium or fee payable at inception, regardless of the delivery or flow of the underlying commodity and the deal is not considered an option, that deal premium or fee, if it pertains to the service the trade is providing and unrelated to the volume of said product, would not be reportable.