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Meeting Multi-Regime Reporting Requirements

10 September 2019

There is a growing concern amongst market participants that their reporting obligations across multiple regimes are becoming increasingly complicated, highly fragmented, and administratively burdensome. Adding to these concerns are repeated instances of financial penalties which are arising for over/under/non reporting, coupled with a number of institutions now exiting from their previously-offered "delegated reporting" service.

As existing global reporting requirements evolve, and new regulatory reporting changes are introduced, clients are finding they must have the ability to report across fragmented legacy systems to many jurisdictions (including ASIC, Canada, CFTC, EMIR, HKMA, MAS and MiFID) across the following asset classes in a scalable and cost-effective manner:

  • Credit
  • Commodities
  • Equities
  • Foreign Exchange
  • Rates

Sample Reporting Requirements

Under the European Market Infrastructure Regulation (EMIR), for example, all counterparties are required to report details of any derivative contract (OTC or exchange traded) they have concluded, or which they have modified or terminated, to a trade repository (TR) that has been registered or recognised by the European Securities and Markets Authority (ESMA). On the 17th June 2019, the EMIR Regulatory Fitness and Performance Programme "REFIT" came into force that (amongst other objectives) streamlined reporting obligations. From 18th June 2020, a financial counterparty will be solely responsible and legally liable for reporting on behalf of both counterparties, the details of OTC derivative contracts concluded with a non-financial counterparty (NFC) not subject to the clearing obligation as specified under REFIT.

MAS Reporting is the term given to the requirement by the Monetary Authority of Singapore for certain firms to report details of their derivatives transactions to a trade repository. The concept of "nexus" reporting is largely specific to ASIA where reportability of a derivative contract is determined by both the "booked-in" location and the "traded-in" location. In Singapore, the derivative reporting regime will be expanded to include Interest and Credit Derivatives contracts traded in Singapore for buy side firms to be reportable to MAS starting from 1st October 2019. Firms will need to review their business to identify and report trades that originate from Singapore trading desks.

Markit Integrated Reporting

The Markit Integrated Reporting (MIR) solution addresses complex regulatory requirements by bringing together transactional, valuation and collateral coverage across all asset classes. Accessed via an intuitive and easy-to-use web interface; MIR provides a one-stop solution offering full reporting workflow across submission, data management, reconciliation and monitoring: sending transactions to numerous Trade Repositories with support for sending to Approved Reporting Mechanisms and Approved Publication Arrangements in a highly straight through processing environment.

Once input sources are identified, the solution can consume data in any formats from any system - whether it's using existing connectivity via IHS Markit; for example DS Match (for Credit Derivatives), MarkitWire (for Rates and Equity Derivatives) or leveraging the extensive and established IHS Markit network across TradeSTP to third party Foreign Exchange platforms - as well as client specific internal systems or a CSV upload via SFTP (for example FX Valuations from Fund Administrators). As each firm has its own bespoke business operation, MIR is fully capable of implementing client specific business rules and static data management with its customizable and flexible rules.

Data is then displayed via an intuitive and consolidated platform for compliance monitoring and control, showing those trades received by the regime and status returned, including visibility on whether a counterparty has submitted their side of the trade.

Finally, the robust workflow is complimented by a dual-factor authorisation process (with complete audit functionality). Information is displayed via a near-real time dashboard that is automatically updated to facilitate at-a-glance monitoring.

Please contact your Account Manager for more information.

IHS Markit provides industry-leading data, software and technology platforms and managed services to tackle some of the most difficult challenges in financial markets. We help our customers better understand complicated markets, reduce risk, operate more efficiently and comply with financial regulation.

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