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