SFTR Transaction reporting. Transparency of Securities Financing Market STRATEGY & MANAGEMENT CONSULTING PARIS LONDON LUXEMBOURG HONG KONG SINGAPORE

Similar documents
SFTR Transaction reporting. Transparency of Securities Financing Market STRATEGY & MANAGEMENT CONSULTING PARIS LONDON LUXEMBOURG ASIA

Aurexia Luxembourg Our Service Offer related to the Insurance Distribution Directive (IDD)

MiFID II. Assessing MiFID II impacts for Corporate & Investment Banks STRATEGY & MANAGEMENT CONSULTING PARIS LONDON LUXEMBOURG ASIA.

Collateral Management

REGIS-TR Securities Financing Transaction Regulation SFTR

The Securities Financing Transaction Regulation (SFTR)

Securities Financing Transactions Regulation (SFTR) Providing a full end to end regulatory reporting solution for SFTs

Opinion On the European Commission s proposed amendments to SFTR reporting standards

GTR. The Reporting Solution for Securities Financing Transactions

EACH response to the ESMA discussion paper Draft RTS and ITS under the Securities Financing Transaction Regulation

COMMISSION IMPLEMENTING REGULATION (EU) /... of

Technical standards under SFTR and certain amendments to EMIR

Revised trade reporting requirements under EMIR June 2017

SFTR: A Trade Repository view from REGIS-TR

Re: SFTR DISCUSSION PAPER/REPORT Draft RTS and ITS under SFTR

THE FRONT-TO-BACK SFTR SOLUTION

Asset Management Director PwC Year-end accounting update. January 2017

SFTR A harder version of EMIR? April Fabian Klar, Business Development Manager, REGIS-TR S.A.

Consultation Paper. Draft RTS and ITS under SFTR and amendments to related EMIR RTS. 30 September 2016 ESMA/2016/1409

ANNEXES. to the COMMISSION DELEGATED REGULATION (EU)

EU SFT Regulation: Key elements and timeline

BVI`s response to the ESMA Consultation Paper Draft RTS and ITS under SFTR and amendments to related EMIR RTS (ESMA/2016/1409)

Link n Learn. EMIR SFT Regulations. Leading Business Advisors

Deutsche Bank Global Transaction Banking. Beyond T2S: Balancing collateral efficiency versus investor protection

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL

Swiss Financial Market Infrastructure Act Frequently Asked Questions How we can help you achieve your reporting obligations

A just-in-time guide to EMIR trade reporting

New EU Regulation on securities financing transactions and collateral reuse (the SFTR)

EFAMA response to the ESMA Consultation Paper on the Draft RTS and ITS under SFTR and amendments to related EMIR RTS

Repo and Securities Lending This course can also be presented in-house for your company or via live on-line webinar

Financial markets today are a global game between a variety of highly interconnected players. Financial regulation sets out the rules of this game.

- To promote transparency of derivative data for both regulators and market participants

Questions and Answers On MiFID II and MiFIR post trading topics

Repo and Securities Lending: The GMRA and GMSLA Provisions

The EU regulation on reporting and transparency of securities financing transactions another piece in the jigsaw of shadow banking regulation

ESMA Risk Assessment Work Programme 2019

Joint ICMA ERCC ISLA industry roundtable SFTR reporting: Implementation challenges and solutions. 8 February 2017

THIS DOCUMENT IS IMPORTANT AND REQUIRES YOUR IMMEDIATE ATTENTION. IF IN DOUBT, PLEASE SEEK PROFESSIONAL ADVICE. Notice to the Shareholders

Final report Technical advice on third country regulatory equivalence under EMIR Hong Kong

Blockchain the real fintech revolution? 26/06/2018 Thiebald Cremers Director Legal and Public affairs, SETL France

COMMISSION DELEGATED REGULATION (EU) /... of

Final Report ESMA Technical advice to EC on fees to TRs under SFTR and on certain amendments to fees to TRs under EMIR

Joining the dots of the new regulatory framework for a better understanding of the new securities infrastructure landscape

Why Regulate the unregulated?

Questions and Answers. ESMA s guidelines on ETFs and other UCITS issues

Questions and Answers ESMA s guidelines on ETFs and other UCITS issues

MiFID II for Non-EU Investment Banks, Brokers and Fund Managers

REGIS-TR the European Trade Repository for Derivatives. 10./11. May 2012 Clearstream CEE Conference

5 November EU Regulatory update. Simon Puleston Jones

Questions and Answers Application of the AIFMD

MiFID II 31 December MiFID II. Derivatives: trade execution

EMIR and DODD-FRANK FAQs. January 2017

Questions and Answers ESMA s Guidelines on ETFs and other UCITS issues

Bank Negara Malaysia Mr. Chan Kah Som Ms. Kathleen Wong

Derivatives Regulation

Derivatives: trade execution

Clearstream Snapshot

Draft Frequently Asked Questions (Draft FAQs) and Draft Supplementary Reporting Instructions (Draft SRIs) Comments

THE IMPACT OF EMIR IS YOUR ORGANISATION READY?

EMIR - What should Hedge Funds be doing?

Reply form for the Consultation Paper Draft RTS and ITS under SFTR and amendments to related EMIR RTS

ESMA s consultation papers on draft regulatory standards under the securitisation regulation Roxana Damianov, Thierry Sessin-Caracci, Adrien Amzallag

ESMA Risk Assessment Work Programme 2018

Reply form for the Consultation Paper Draft RTS and ITS under SFTR and amendments to related EMIR RTS

CSD Regulation Settlement Discipline: mandatory buy-ins

Navigating Regulatory Compliance Investment Management Monthly Regulatory Update. April 2016

Consultation Paper ESMA s Guidelines on position calculation under EMIR

Territorial Scope of Reporting, Clearing and Trading

Securities Financing Transactions: Case Study on the Situation in Switzerland

comments on Consultation Paper 26 Jul 2012

MiFID II Solutions. IHS Markit s comprehensive set of solutions to meet MiFID II requirements

ICE Clear Europe CDS Regulatory Reporting Static Details Description

ESMA Publishes Draft Regulatory Technical Standards on Cross-border Application of EMIR

February 24, CPMI Secretariat Bank for International Settlements Centralbahnplatz Basel Switzerland Via

Are you ready for EMIR? October 2013

Consultation Paper. Clearing Obligation under EMIR (no. 6) 11 July 2018 ESMA

ESMA s 2019 Regulatory Work Programme

Regulations affecting data management

Swiss Financial Market Infrastructure Act FMIA / FinfraG

Newsletter. Financial Sector. September 2016 CONTENTS. Grant Thornton BPO Solutions for FATCA / CRS / QI

SCOPE OF SECTION C(10) CONTRACTS WHICH ARE "COMMODITY DERIVATIVES" FOR THE PURPOSES OF MIFID II

a central counterparty, the registration and supervision of trade repositories and the requirements for trade repositories

MAJOR NEW DERIVATIVES REGULATION THE SCIENCE OF COMPLIANCE

EMIR Trade Reporting Additional Recommendations

A strategic approach to global derivative trade reporting

NASDAQ S BLOCKCHAIN AND THE ENABLEMENT OF COMPETITIVE ADVANTAGE

COUNTERPARTY CLEARING SYSTEM IN EUROPE

INSURANCE INNOVATION EXECUTIVE BOARD

RECOMMENDATIONS ON THE HARMONISATION OF THE COVERED BOND FRAMEWORKS IN THE EU. Christian Moor, European Banking Authority

MiFID II/MIFIR Readiness

Update on proposed EU regulation as regards FX derivatives transactions

European Market Infrastructure Regulation (EMIR) - Impact on Market Participant s Business Operations & Technology Landscape

Alert Memo BRUSSELS AND LONDON, DECEMBER 28, Reform of the Markets in Financial Instruments Directive: European Commission Consultation

2017 FinTech Predictions. December 2016

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL

Keynote Address. AFME European Compliance and Legal Conference London. Verena Ross Executive Director. Ladies and gentlemen,

MiFID2 Extraterritorial Impact on FIs and AMIFs. Charlotte Stalin Jason Valoti

EFET Approach Regarding Unresolved EMIR Implementation Issues 2 May 2013

Consultation Paper Review of Article 26 of RTS No 153/2013 with respect to MPOR for client accounts

ASSOSIM. Consultation paper - ESMA s guidelines on ETFs and other UCITS issue

Transcription:

SFTR Transaction reporting Transparency of Securities Financing Market STRATEGY & MANAGEMENT CONSULTING PARIS LONDON LUXEMBOURG HONG KONG SINGAPORE

Contacts Dominique Herrou, Luc Estang Your contacts to discuss SFTR reporting: Dominique HERROU Partner Tel: +33 (0) 6 77 94 48 14 Tel: +65 8313 6610 dominique.herrou@aurexia.com Luc ESTANG Senior Manager Tel: +33 (0)6 40 08 38 58 luc.estang@aurexia.com 2

Context & objectives Reporting obligation SFTR transaction reporting EMIR like reporting obligations for securities financing transactions Following the global financial crisis, the ESRB and the European Commission have explored various ways to regulate the so-called «Shadow Banking» sector. Scope The EU Securities Financing Transactions Regulations (SFTR) came into effect on 12 January 2016 and aims at regulating and increasing the transparency of securities financing transactions in three ways: By requiring counterparties to report SFTs to a EU approved trade repository By imposing condictions on the Collateral re-use. The collateral provider has to give explicit writing consent about risks & consequences of such agreement. By requiring Funds managers to inform investors of their use of SFTs and total return swap in their reports (pre-investment documentation, periodical reports) Reuse requirements and reports transparency obligations respectively came into effect on 13 July 2016 and 13 January 2017. The reporting obligation follows a phased-in approach over a period between 12 to 21 months after the RTS comes into force. Consequently, the reporting obligation should start in 2018 assuming RTS will entry into force in Q4 2017. EU legal entities Products Branches of EU legal entities regardless of their location EU branches of third country counterparties Repurchase transactions for securities, commodities and guaranteed rights; lending & borrowing transctions on securities & commodities; buy sell back & sell buy back of securities, commodities & guaranteed rights; margin lending transactions Reporting Individual securities financing transaction have to be reported by both sides of the transactions to a EU approved trade repository the day after the transaction at the latest 3

Reporting timeline Ground work should start now to be ready for Q4 2018 The actual start date of the reporting obligations depends on RTS reporting requirements. The reporting will start 12 months (Banks & IF), 15 months (CCPs & CSDs), 18 months (Insurance & funds) and 21 months (non financial counterparties) after RTS entry into to force. 12 January 2016 Q2 2018(est) Q3 2019 (est) Q1 2020 (est) SFTR entry into force Final RTS entry into force CCPs & CSDs RTS + 15 months Non financial counterparties RTS + 21 months 2018 2020 2016 2019 Q2 2019 (est) Q4 2019 (est) Banks & investment firms Insurance, firms, UCITS, AIFs & pension funds RTS + 12 months RTS + 18 months 4 Dates are subject to the legislative process

Transaction reporting requirements SFTR transaction reporting generally follow the same structure as EMIR for derivatives What Who When? To whom? What data? New, modified or terminated SFTs are to be reported to an approved trade repository by t+1 Obligation applies to existing trades : those concluded before the reporting start date (SD) with a remaining maturity of 180 days & open trades 180 days after SD Both parties to a trade must report Financial counterparties dealing with SMEs report on behalf of these counterparties Funds manager must report on behalf of their funds Possibility to delegate the reporting SFTs transactions must be reported by T+1 Trade repositories registered or recognized for SFTR ESMA otherwise SFT parties UTI Principal amount and currency Securities lent/borrowed Asset used as collateral, type, quality and value Method used to provide collateral Availability fo re-use & reused Y/N Repo,lending fee / rebate rate or margin lending rate Haircut Value date, maturity date & first callable date Market segment 5

Challenges RTS draft has highlighed data & technology challenges for the reporting implementation Gather & structure disparate trade data Many of the fields presented in the level 2 draft may not electronically stored and/or easily available, to name a few: collateral maturity dates, issuer credit ratings, information related to re-use eligibility and actual re-use Capture the LEI If many market participants already have a LEI code, they still need to consider upgrading their systems to capture and populate the LEI codes for existing transactions. Generate & assign UTI The Industry has to agree on how and when the UTI will be assigned during the transaction lifecycle. The connectivity will need to be set up to capture it in a timely manner. Determine the reporting party Even tough SFTR is a two sided reporting, there are many cases where only one party will report. Ex: the Belgium branch of US borrower will take charge of the report when facing a Japanese lender. This logic needs to be set up in the reporting system. 6

Aurexia in a nutshell About our company - Established in 2006 - A decade of global management consulting for the Banking and Insurance industries CAPITAL MARKETS SECURITIES SERVICES Text TRANSACTION BANKING ASSET MANAGEMENT PRIVATE BANKING RETAIL BANKING INSURANCE FINANCE RISK MANAGEMENT - Aurexia Institute - Frequent market studies published on: Business matters Regulatory watch Process improvement insights Text Architecture benchmarks Follow us on: - Digital Lab - - International - A pragmatic vision of disruption: Robotics / AI Fintech Ecosystem Blockchain Text 5 local offices to support our clients globally: Paris - London Luxembourg Singapore Hong Kong WWW.AUREXIA.COM 7

Our Digital Strategy A comprehensive lab, from research to clients implementation VENDORS BENCHMARKS SKILLS - TRAINING BEST PRACTICES MARKET INTELLIGENCE PROOFS OFCONCEPT ROBOTICS - AI POC Deep learning Business strategy Robot based target processes Machine learning Cost savings RPA factory Eligible Process Review Blockchain processes Distributed ledger Public / Private Application per business area Smart contracts Network FINTECH ECOSYSTEM Partnerships Winners Innovation Fintech Awards Fintech ecosystem data base Regtech Pushing boundaries Investors Insurtech Entrepreneurships BLOCKCHAIN BUSINESS & INNOVATION PROCESSES OPTIMIZATION REGULATORY EFFICIENCY ARCHITECTURE 8

They trust us Major institutions in the banking and insurance industries 9

Our Offices Worldwide locations PARTNER Dominique HERROU EUROPE ASIA PARTNER Éric VERNHES PARTNER David VILLARD Swann REDSLOB LONDON 1 Fore Street London EC2Y 5EJ +44 (0)6 7464 545 167 LUXEMBOURG 9 rue Large, L-1917 Luxembourg +352 691 121 832 Alain de CIDRAC SINGAPORE 96 Robinson Road #11-04 SIF Building Singapore 068899 + 65 8313 6610 Dominique HERROU Ludovic DUFETEL HONG KONG Luard Rd, 23-21/F The Phoenix Wan Chai, Hong Kong +65 9753 3672 PARTNER Charles BAIN de la COQUERIE COO PARIS 62 rue de Caumartin, 75009 Paris + 33 (0)1 42 66 27 38 Caroline SMADJA 10

Partners Offices Dominique Herrou +65 8313 6610 dominique.herrou@aurexia.com Charles Bain de la Coquerie +33 (0)6 80 37 32 15 charles.baindelacoquerie@aurexia.com Paris Office 62 rue Caumartin, 75009 Paris, France +33 (0)1 42 66 27 38 Luxembourg Office 8-10 Avenue de la gare L-1610 Luxembourg +352 (0)691 121 832 Eric Vernhes +33 (0)6 86 51 54 76 eric.vernhes@aurexia.com David Villard +33 (0)6 75 53 19 47 david.villard@aurexia.com London Office 1 Fore Street, London EC2Y 5EJ, United Kingdom +44 (0)2 080 042 027 Asia Office 96 Robinson Road #11-04 SIF Building Singapore 068899 www.aurexia.com/en 11 AUREXIA