MiFIR Review confirmed on track

As expected, ESMA published its first conclusions on December 16th 2024, following the consultations launched in the second quarter of last year. From a reporting point of view, only Post Trade Transparency (RTS 1&2) and Commodity Position Reporting (MiFID II art. 58) were concerned, whereas the main topic, namely Transaction Reporting (RTS22) was supposed to arrive later in March. The European Commission has 3 months to approve the proposals to modify the RTS (Regulatory Technical Standard) but we can already say that the consultations have not fundamentally changed ESMA's proposals. The APAs (Approved Publication Arrangement) which collect and publish transactions in accordance with the rules of Post Trade Transparency (RTS1&2), will have to adapt and quickly communicate their format changes. Regarding Commodity Position Reporting (MiFID II art. 58), FinTeX Factor:y currently supports reporting to “ICE Futures Europe” which depends on the FCA and UK-Mifid II (not in-scope of Mifid II-MiFIR Review which is purely European), with further extension plans for 2025.

By | February 10th, 2025|MiFIR, Regulatory Reporting|0 Comments

MiFIR Review is on track

Even before EMIR REFIT entered into force, the European Parliament published its Directive (EU) 2024/790 and Regulation (EU) 2024/791, called “MiFID II / MiFIR Review”, and already nicknamed “MiFID III / MiFIR II” or “MiFIR REFIT”. The text applies as of March 28th 2024, but “Several provisions in the MiFIR review need to be supplemented by Commission delegated regulations to become fully operational”.Concerning the reporting which is what is interesting us, Post Trade Transparency (RTS 1&2), Position Reporting (MiFID II art. 58) and of course, Transaction Reporting (RTS 22), the consultation process is running, and Final reports are expected in December 2024 and March 2025. We will then have a clearer view of the timeline, as the Commission explains in its draft notice that the set of rules applicable to reporting will become applicable as soon as the revised RTS starts applying and in the meantime the rules prior to the MiFIR Review will continue applying. Reading carefully the ESMA consultations, we can already expect substantial changes, particularly on the Transaction Reporting side. More to come early next year, keep in touch!

By | December 3rd, 2024|EMIR, Regulatory Reporting|0 Comments

FinfraG REFIT expected in 2025

On June 19th, the Swiss Federal Council launched a consultation on the modification of the Financial Market Infrastructure Act (FMIA), also known as FinfraG (in German), or LIMF (in French). As the consultation ended a few weeks ago on October 11th we expect the conclusions to be published very soon. FinfraG covers both the derivatives reporting via the article 104 (the equivalent of EMIR in the EU or UK), but also transaction reporting via the article 39 (the equivalent of MiFIR for EU). Considering the amendments (see details in the Swiss Federal Council link below) proposed by the Federal Department of Finance in charge of evaluating and modifying the law, it is unlikely that the consultation fundamentally changes the core project. We therefore anticipate a REFIT-like version of the derivatives reporting and the transaction report in 2025. We will keep you informed of upcoming changes in the near future post. Stay tuned! Swiss Federal Council post: https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-101490.html

By | November 7th, 2024|EMIR, Regulatory Reporting|0 Comments

MAS Rewrite in force since monday Oct 21st!

MAS Rewrite is already behind us. Let's recognize DTCC had a much smoother start compared to EMIR REFIT, with a particularly well-managed stock migration, a key point we already mentioned in a previous post. 2024 was a very busy year with several REFIT (REgulatory FITness and Performance Program) concerning EMIR, EMIR UK and MAS. Let's focus now on 2025 which just looks as intense as this year!Several regulatory reporting changes are already planned. Some for which we already know the target date, like HKTR at the end of September or CFTC. And others which are still in the consultation phase such as FinfraG or MiFIR but for which we already anticipate major changes.

By | October 24th, 2024|EMIR, Regulatory Reporting|Comments Off on MAS Rewrite in force since monday Oct 21st!

EMIR REFIT Transition period

ESMA 180 calendar days transition period will end next October 26th. All the “legacy” outstanding derivatives (Meaning, reported before April 29th 2024, with the preceding EMIR regime) have to be resent to a Trade Repository, using the special EventType “Update”, to comply with the EU EMIR REFIT technical standard. If you have specific concerns or questions about the implications of this deadline, in particular if you encounter difficulties to define the right perimeter of transactions to be resent, we certainly can help you!

By | October 18th, 2024|EMIR, Regulatory Reporting|0 Comments

EMIR Refit UK comes into force on Sept 30th

Only a few days left until EMIR Refit UK goes live. Bespite the content is largely identical to EMIR Refit EU, one must still pay attention to the output file format sent to the Trade Repository. In both cases, XML files format follows ISO 20022 standard, but the ESMA and the FCA have each provided their own file grammar (in technical terms, the XSD file which is the XML schema to comply with).Beware, some adjustments in the EMIR Refit UK output file generation might be required to respect the XSD file structure!

By | September 19th, 2024|EMIR, Regulatory Reporting|0 Comments

MAS Rewrite, getting closer to go-live

If we believe the statistics provided by DTCC on the UAT website, the current rate of accepted reports is relatively low, barely more than one third (36%).After a few weeks of fine tuning, FinTeX Factor:y platform is very proud to disclose its statistics.If you want to get closer to 100% like us, we certainly can help you!

By | September 4th, 2024|MAS Rewrite|Comments Off on MAS Rewrite, getting closer to go-live

MAS Rewrite, DTCC data migration Dry Run

June 14th was the last day to send trades in the MAS DTCC Legacy environment for the first Dry Run.Unlike what was done under EMIR Refit by the main Trade Repositories, DTCC is performing a Dry Run to migrate data from the Legacy to the Rewrite environment, in order to ensure trades format is valid. DTCC gave clear instructions: the trades must comply with the ISO XML standard and certain characters are prohibited. This will avoid what many customers have experienced under EMIR Refit, ie. data partially migrated to the Refit environment, which created side effects (in particular, the inability to send valuations). We welcome the Dry Run initiative from DTCC and are excited to get the first results on June 18th. Another data migration Dry Run based on production data is expected later in July or August. This one will look more like a dress rehearsal.

By | June 18th, 2024|EMIR, Regulatory Reporting, MAS Rewrite|0 Comments

MAS Rewrite, the next challenge

The Monetary Authority of Singapore’s new version of its OTC derivative reporting, “MAS Rewrite”, will go live in October 2024.As MAS aims at aligning with other regulators, Rewrite introduces some concepts that we are already familiar with, following EMIR Refit implementation. We have identified, among the main points of attention: alignment to global UTIs and UPIs standards generalization (less exemption) of collateral reporting reportable fields extension to 134 reporting of FX Swaps as two separate transactions linked through the “swap link Id” ISO 20022 XML messaging format More to come as we are getting prepared for the DTCC UATs on June 14th.

By | May 29th, 2024|MAS Rewrite, Regulatory Reporting|0 Comments

EMIR REFIT is behind us.

Congrats to those who went through this major milestone without experiencing any reject from the Trade Repository! Our clients using FinTeX Factor:y solution had to deal with some rejects on ETDs valuation concerning the stock of open positions reported in EMIR legacy version that must continue to be kept alive (Valuation update, Modification, Exercise, aso.). Like them, you certainly faced similar problems with stock transactions (sometimes in a large proportion) that required to be updated at the Trade Repository to ensure they continue to be reported correctly (Valuation in particular). And although the regulator tolerates a 180-days period to make the stock compliant (ITS Article 10(2)), the flexibility and agility of Factor:y allowed our clients to fix these issues right after go-live, as our solution allows them to send the necessary update events quickly and effectively.

By | May 17th, 2024|EMIR, Regulatory Reporting|Comments Off on EMIR REFIT is behind us.

EMIR REFIT : 2 weeks before go live!

Didn't you get a headache wondering how to populate Field 2.4 "Subsequent Position UTI"? The complexity comes from the fact that EMIR REFIT has introduced dependencies between reports. For example, some particular types of transactions such as novation or compression must refer to the UTI of the initial transaction. Similarly, the “Inclusion in a Position” concept, which is almost generalized for ETDs, imposes that any transaction must refer to the UTI of the position in which it is included. A potential difficulty for those who have to aggregate data (transactions and positions) from different information systems. Factor:y by FinTeX relies on a comprehensive and normalized data model which makes this kind of obstacle much easier to overcome!

By | April 12th, 2024|EMIR, Regulatory Reporting|Comments Off on EMIR REFIT : 2 weeks before go live!

EMIR REFIT: 1 month remaining

“Third Country Organized Trading Platform”, this is a key point Knowing whether the trade was made on a “Third Country Organized Trading Platform” is one of the key points of EMIR REFIT reporting, because it has an impact on several fields, starting from field 3, "Entity Responsible for reporting", 2.29 "Confirmed", 2.30 "Cleared obligation", 2.37 "Intragroup", to the most famous one, field 2.8, the UPI ! As of today, there is no clear answer, even from the Trade Repository. The reason is that ESMA provided a mapping file which was not precise enough, as based on the Exchange common name rather than its MIC Code (https://www.esma.europa.eu/sites/default/files/library/equivalent_tc-markets_under_emir.pdf). From our standpoint, the “Third Country Organized Trading Platform” notion is to avoid having to populate these fields and in particular the UPI for non-isinized ETDs (especially on american markets). But we are waiting for confirmation of our interpretation from ESMA. Did you come across the same issue? #EMIRRefit #EMIR #REFIT #TransactionReporting #RegulatoryReporting #RegulatoryCompliance #Regtech #PortfolioCode #UTI #UPI

By | March 28th, 2024|EMIR, Regulatory Reporting|0 Comments

EMIR Refit

D-40! EMIR Refit becomes effective on April 29. Factor:y, FinTeX's regulatory reporting solution is ready, under UAT validation at our clients. The subject of new fields having been widely covered, we are focusing today on data format changes. As you all aware, the format of identifiers is now much more restrictive: pure alphanumeric, without any special characters. You therefore had to deal with managing the history of transactions reported under EMIR. ESMA lets us use special characters to manage already reported UTIs (field 2.1) during the 180 days transition period. However, this is not the case for the Collateral Portfolio Code (field 2.27). If like us, you have special characters in your historical data, it's time to fix them. Tell us your issues in the comments, we will be delighted to share our expertise! #EMIRRefit #EMIR #REFIT #TransactionReporting #RegulatoryReporting #RegulatoryCompliance #Regtech #PortfolioCode #UTI #UPI

By | March 15th, 2024|EMIR, Regulatory Reporting|0 Comments