Communication on MiFID II Client Pack

What is it?

The MiFID II Pack includes:

• A notification on the client’s category under MiFID II
• Link to MiFID II portal on Societe Generale or Societe Generale International Limited (SGIL) Website
• Update of our Terms of Business regarding provision of Research and Direct Electronic Access, or SGIL regulatory patch to complement existing Terms of Business
• Several consents that are required under MiFID II:
  • Consent to use email communications
  • Consent to limit orders
  • Consent to various best execution policy
  • Consent to deferred receipt of suitability report in case of investment advice
  • Consent to disclosure of your identity (to NCA and execution venues)
  • Consent to handle and execute an order outside a trading venue (this consent requires an express consent from you via the consent letter)
• For SGIL only, consent for right of re-use (not linked to MiFID II but local FCA regulation)
• Reminder on the requirement to obtain a Legal Entity Identifier (LEI)

What do we need from you?

We need you to sign and return the consent letter.
Important - if you are not a retail or professional client, you do not need to sign the consent letter. If you are not in contact with any sales of Societe Generale in the EU nor not a client of SGIL, you are not obliged to return this letter to us either. However we still recommend you to sign it and return it asap so as to ensure that our sales in Europe can assist you should your wish or need them to execute an order in the future.

Communication on LEI

What is it?

The LEI is required for the purposes of executing trades on trading venues and reporting them. If you don’t have a LEI we will not be able to execute your transactions (if existing client) or to onboard you (if new client).

We need to obtain your LEI if you conduct trading activities in the EU or activities involving instruments available for trading on EU trading venues, you will need to provide us with your legal entity identifiers (“LEI”). 

Important note:transaction reporting requires the disclosure of the client’s identity. It should not be confused with post-trade transparency (which is to be made on an anonymous and aggregated basis). 

How to get a LEI?

An LEI is usually issued within 24 to 48 hours of application. Registration costs (about USD 220). A LEI needs to be renewed on a yearly basis.

Our LEI
The LEIs of Societe Generale and some of its affiliates

Communication and questionnaire on Direct Electronic Access, High Frequency and Algorithmic trading

What is it?

There is a questionnaire on DEA, and depending on your business, you may also have received information on Societe Generale MiFID II FIX Specifications (addressed to a technical audience).

What is it for?

New data are required to be uploaded in the trading systems, such as Client short code, Trader Name, Algo short codes, and certain data need to be uploaded by us to exchange portals (LEI, client short code and long name).

What do we need from you?

In order for us to populate it to the trading venue, with the support of relevant Independent Software Vendors (CQG, Fidessa, TT and WebICE), we need to obtain some information from you, including whether you are using Algorithmic trading or not, which ISV you use, whether you provide order transmission services for other clients, whether you meet the test for HFAT or not, the default value for your commodities trades (hedge or spec.), etc.

We also need to obtain a number of information from you as part of the obligation to certify your FIX connections (please refer to our specific document for further detail).

What is our short code?

Our DMA clients using the services of one of the 4 independent software vendors (ISVs) have to use our short code.

Communication on Indirect clearing

What is it?

The purpose of this communication is to identify direct clients of Societe Generale or Societe Generale International Limited (SGIL) which are providing indirect clearing services to their clients through us on an EU CCP, and how many entities there are between the EU CCP and the end client.

What is it for?

Clearing members are subject to some disclosure requirements (applicable terms and conditions, levels of protection and costs associated therewith, main legal implications of different levels of segregation available), account requirements (to offer direct clients the choice of a basic omnibus indirect client account or a gross omnibus indirect client account, and to implement a default management process in case of a default of a direct client).

Direct clients providing indirect clearing services are also subject to some similar requirements on disclosure (details of levels of segregation) and accounts (offer indirect clients the choice of a basic omnibus indirect client account and a gross omnibus indirect client account).

What do we need from you?

We need information on your activities, such as whether or not you provide indirect clearing to EU CCPs to your affiliates and/or clients. One of the purposes is to assess the length of the clearing chain between the EU CCP and the end client.

We need to get your instruction on the type of account you wish us to open (GOSA/NOSA).

Communication on commodity position reporting

What is it?

In order to comply with its reporting obligations, we require additional data from you:

What is it for?

Clearing members are liable to report the trades of their clients on a daily basis, including whether the trades are hedge or speculative.

What do we need from you?

• Non-financial entities (NFEs) will be required to categorise positions as either “Hedge” or “Speculative” or a combination of both. Reporting requirements include the need to flag whether the position is risk reducing* in relation to commercial activity.
• Legal Entity Identifier (LEI) (if not already provided)
• Email address in order for the local regulator to be able to send you notifications of position-related matters (without clear guidelines from ESMA, the market consensus is to require a compliance officer’s email address)
• LEI and email address of your “ultimate parent entity”.
• If you are a collective investment undertaking, you will need to confirm whether you make investment decisions independently from your parent undertaking.