Trader Identification Requirements

Frequently Asked Questions

March 2017

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This document provides general guidance on the requirements for the identification of electronic
traders, including the population of WebICE User IDs, FIX User IDs, Authorized Trader IDs
(“ATIDs”), and entry of information pertaining to ATIDs into the Authorized Trader Management
System (“ATMS”). Note that the Rules should always be consulted in conjunction with any guidance
document, and supersede any information in the guidance document.

Traders Generally

Q1: How are electronic traders identified?

A1: For activity in the central limit order book (“CLOB”), access to the ICE trading system is facilitated
using either WebICE or a FIX connection. There are also methods by which trading access may
occur to non-CLOB systems, such as ICE Block, but they are not intended to be addressed in this
document.

A unique identification is required for any trader that manually (key-punches) or automatically submits
an order to the ICE trading system.

Traders who access the market through WebICE will have a WebICE User ID, whereas traders who
access the market through a FIX connection will have a FIX User ID (FIX Tag 9139) along with an
Authorized Trader ID (FIX Tag 116 Right).

WebICE requirements

Q2: How are WebICE User IDs assigned?

A2: Firms with direct access to ICE’s front-end (“Direct Access companies”), electronically request
and are issued WebICE User IDs for individuals, by ICE User Administration. The Direct Access
companies then assign the WebICE User IDs to their employees or clients, whose identifying
information has been provided to ICE User Administration as part of the ID request.

Q3: May more than one person use a single WebICE User ID?

A3: No. Each trader must have their own unique WebICE User ID that cannot be shared.

FIX requirements

Q4: How are FIX User IDs assigned?

A4: Direct Access companies electronically request and are issued FIX User IDs by ICE User
Administration. The Direct Access company then takes the steps necessary to enable these IDs for
its employees or clients, either directly or through their independent software vendor.

A responsible person is assigned by the Direct Access company to each FIX User ID. This person
must have the authority to modify or withdraw any order submitted under any FIX User ID assigned to
such person and must have the ability to address any issues related to orders routed through that ID.

Authorized Trader ID requirements

Q5: What is an Authorized Trader ID?

A5: An Authorized Trader ID, or “ATID”, is a regulatory “tag” (data field), contained in FIX Tag 116
Right, for any trader that is connecting to the ICE trading system via a FIX User ID. For the avoidance
of doubt, the ATID is the value populated to the right of the “pipe” character in Tag 116
(OnBehalfOfSubID). The value populated to the left of the pipe (Tag 116 Left) is Routing Trader ID,
and is not a permissible substitution for Authorized Trader ID (Tag 116 Right).

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The ATID field is populated by the trader’s front-end trading system, and must contain a unique value
for the trader who is physically submitting an order, or for the Automated Trading System (“ATS”)
submitting an order. ATIDs cannot be shared between individuals, other than for Automated Trading
Systems as noted below.

All traders who submit orders through a FIX connection to the ICE trading system must have a unique
ATID assigned to them. This requirement exists irrespective of whether the trader or their employer is
a registered member/participant of the Exchange.

Q6: Does all electronic trading occur through ATIDs?

A6: No. ATIDs are only applicable and required for FIX connections. ATIDs are not applicable to
WebICE User IDs.

Q7: Is an ATID the same as a FIX User ID?

A7: No. FIX User IDs are generated by ICE User Administration, upon request by a Direct Access
company, and are the identifier by which a FIX login occurs to the ICE trading system. The same FIX
User ID may be used by multiple individual traders to log into the trading system.

By contrast, ATIDs reside under the FIX User ID, and identify individual traders submitting orders
through the FIX User ID. ATIDs are created and populated by the Direct Access company, or in some
cases the client’s front-end software.

Note that, from a FIX trader’s perspective, the population of the FIX User ID and ATID may not be
directly visible to them. Instead, these data fields may be associated with their local login information,
and pushed to the trading system when they connect.

Q8: Can Authorized Trader IDs be shared by multiple individual traders?

A8: No. Exchange rules require that all individual traders who manually enter orders (the “button
pushers”) have a unique ATID assigned to them. Only in circumstances involving Automated Trading
Systems may there be more than one person associated with a single ATID.

Automated Trading Systems

Q9: How are ATIDs populated for Automated Trading Systems?

A9: An Automated Trading System (“ATS”) is a system that automates the generation and
submission of orders to the ICE trading system, without human intervention.

An individual who administers and/or monitors the ATS is considered to be an ATS operator. This
person typically initiates or disables algorithms, adjusts the parameters of the automated program(s),
and/or monitors the live trading of the ATS. All ATS orders must be submitted with an Authorized
Trader ID that identifies the person who operates, administers, and/or monitors the ATS.

If there are multiple individuals who operate the ATS, they may qualify to be a “Shared ATS” and
assign a single Authorized Trader ID that represents all individuals in the group. For example, a firm
may have one person who adjusts pricing parameters, but others who continuously monitor
positions/risk or adjust trading size parameters. In these situations, the individuals using the Shared
ATS may use a single Authorized Trader ID.

Q10: What if an ATS has multiple strategies?

A10: An ATS may submit orders from multiple underlying strategies, under the same Authorized
Trader ID, only if the same individual or team has primary responsibility for the operation of all

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strategies under that ATID, and there is no possibility of the ATID trading against itself. If both of
these conditions cannot be met, then each strategy must submit orders through a separate ATID.

Q11: How are manual orders, entered by an ATS operator, to be managed?

Q11: Manual orders, entered by an ATS operator, must be entered under a separate ATID from the
main ATID under which the algorithm automatically submits orders.

Q12: Do orders generated by an auto-spreader require a separate Authorized Trader ID?

A12: No. If a trader enters orders manually, but also uses automated spreading functionality or other
similar front-end software on an ancillary basis, then a separate ATID is not required for the auto-
spreader orders.

ATMS

Q13: What is ATMS?

A13: ATMS is a database management system used to identify the individuals associated with
Authorized Trader IDs (ATIDs) for certain market participants who are required to register. ATMS is
not used for WebICE User IDs.

Q14: Do all traders have to be registered in ATMS?

A14: No. WebICE User IDs do not require registration in ATMS. Furthermore, certain traders using
FIX connections do not need to be registered in ATMS. See below for more information.

Q15: Which traders, using an ATID through a FIX connection, must be registered in ATMS?

Exchange ATIDs required to be registered in ATMS

ICE Futures • Individual IFCA Participants, in any category;
Canada (IFCA) • Employees of companies registered as IFCA Participants, in any category;
• Individuals registered in the Non-Direct Access Liquidity Provider Program;
• Employees of companies registered in the Non-Direct Access Liquidity
Provider Program;
• Any other trader that the relevant Exchange Regulatory Division
determines should be registered in ATMS. Notice will be provided to the
relevant individuals, if this determination is made.
ICE Futures • Individual IFUS Members;
U.S. (IFUS) • Employees of individual Members, Clearing Members, non- clearing
Member Firms and any Person with Direct Access;
• Individuals or employees of firms who participate in an Exchange market
maker, market specialist or fee program;
• Any other trader that the relevant Exchange Regulatory Division
determines should be registered in ATMS. Notice will be provided to the
relevant individuals, if this determination is made.
ICE Futures • Individual IFEU Members;
Europe • Employees of individual Members, clearing Members, non-clearing
Members and any person or non-Member with Direct Access to the ICE
Platform (under the terms of the Electronic User Agreement or the Direct
Access Interface Development and Maintenance Agreement);
• Individuals or employees of firms who participate in an Exchange market
maker, or fee program;
• Any other trader, person, company or market participant not specified
above that the Exchange determines should be registered in ATMS.
Notice will be provided to the relevant individuals, if this determination is
made. Persons may be obligated to register their Authorized Trader ID in

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ATMS even if they are not otherwise required to register with the
Exchange.
ICE Endex • Individual Members of ICE Endex Markets B.V. and ICE Endex Gas Spot
Ltd;
• Employees of individual Members, clearing Members, non-clearing
Members and any person or non-Member with Direct Access to the ICE
Platform (under the terms of the Electronic User Agreement or the Direct
Access Interface Development and Maintenance Agreement);
• Individuals or employees of firms who participate in an Exchange market
maker, or fee program;
• Any other trader, person, company or market participant not specified
above that the Exchange determines should be registered in ATMS.
Notice will be provided to the relevant individuals, if this determination is
made. Persons may be obligated to register their Authorized Trader ID in
ATMS even if they are not otherwise required to register with the
Exchange.
ICE Futures • Employees of clearing Members, non-clearing Member Firms and non-
Singapore Member Firms directly accessing the Exchange Platform (under the terms
(IFSG) of the Electronic User Agreement or the Direct Access Interface
Development and Maintenance Agreement);
• Market Makers of the Exchange;
• Any other trader that the Exchange determines should be registered in
ATMS. Notice will be provided to the relevant individuals, if this
determination is made.

Q16: Who is responsible for entering information on ATIDs into ATMS, and how do you enter
this information?

A16: Direct Access companies who are issued FIX User IDs are responsible for obtaining information
about the ATIDs under their FIX User IDs, and ensuring the information is entered into ATMS. More
information on accessing and using ATMS can be found in the ATMS User Guide:
https://www.theice.com/publicdocs/ATMS_User_Guide.pdf

Q17: What information must be submitted in ATMS?

A17: All information fields in ATMS (as noted in the User Guide) should be populated, where
applicable. This includes, but is not limited to:

• The individual trader’s full name;

• The trader’s employing company, if applicable. This is not (necessarily) the Direct Access
company entering the information; it is the actual employer of the trader. If the employing
company is not listed, consult the ATMS User Guide for instructions on adding a company;
• The trader’s email address;
• The trader’s phone number;
• The trader’s physical location (country);
• For ATIDs that are used for Automated Trading Systems (ATSs), the “ATS” box must be
selected. Note that this is the only permissible situation where more than one individual can
be assigned to a given Authorized Trader ID. See other parts of this guidance document for
additional ATS information.
• The trader’s role in the organization. For non-ATS situations, this will typically be “Trader” or
“Head Trader”. However, for ATS, it may be other supporting roles for those who monitor the
ATS.

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Q18: When must information be entered into ATMS?

Q18: There is an obligation on the companies and individuals noted in Question 15, and the Direct
Access companies through which they trade, to ensure information is populated into ATMS as soon
as it becomes required. For the avoidance of doubt, this information should be entered into ATMS
prior to using the ATID for order entry.

Direct Access companies have a responsibility to enter information into ATMS as soon as they
become aware that a trader accessing through their connection is required to be in ATMS. That is,
when the Direct Access company becomes aware that a trader meets the criteria noted in the table in
Question 15, then the company should obtain the required identifying information and update ATMS
as soon as possible thereafter.

Market participants also have an obligation to advise their Direct Access company of new ATIDs that
are populated for their employees, and provide the identifying information necessary for creating the
ATMS record, as soon as those employees begin trading. Market participants must co-operate and
work pro-actively with their Direct Access company, to ensure there is not a breach of the ATMS
requirements.

Q19: What is required for Automated Trading Systems?

A19: When registering the Authorized Trader ID for an ATS in ATMS, there will be an ATS indicator
(checkbox) that must be selected. At least one individual must be assigned to the ATS, in ATMS. For
shared ATS registrations, ATMS allows for the input of the relevant individual registration information
for each team member, and also allows designation of each team member’s role. The available roles
include Head Trader, Trader, Trade Monitor, Risk Monitor, Technical/Programmer and Other. If there
are changes to the composition of the Team, it is the responsibility of the ATS operator to
communicate that information to the Direct Access company, to ensure that those changes are
promptly and accurately reflected in ATMS.