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17 June 2013
EMIR
Are you prepared to report your
derivatives transactions ?
© 2013 Deloitte Tax & Consulting
Xavier Zaegel
Deloitte Luxembourg
Are you prepared to report your
derivatives transactions?
© 2013 Deloitte Tax & Consulting 3
Reporting of any derivatives to Trade Repository is one of the
main requirement introduced by EMIR
Today’s objectives
EMIR
Clearing
Standardised OTC
derivatives will need to be
processed through Central
Clearing Counterparties
(CCP)
Reporting
OTC
and traded derivatives
positions
to a
Trade Repository
(TR)
Ancillary impacts
in terms of
regulatory capital
requirements (CRD
IV provisions) for
credit institution or
collateral treatment
for investment firms
1
3
4
Risk
mitigation
techniques
(bi-lateral OTC):
- Timely confirmation
- Portfolio compression
- Portfolio reconciliation
- Mark-to-market valuation
- Dispute resolution
- Collateral requirements
2
• Highlight the EMIR Reporting
Requirements and go through
practical cases
• Review Trade Repository Services
Offering – Regis TR
• How SWIFT can help you to
connect to TR ?
• What I need to do as from now ?
Key take away
© 2013 Deloitte Tax & Consulting 4
Agenda
Theory vs. Practice: Key Requirements & Case Studies 2
Regis TR 3
SWIFT 4
5
Are you prepared to report your derivatives transactions? 1
Q&A - Panel
6 What’s Next: Challenges and Opportunities - Linking the dots
© 2013 Deloitte Tax & Consulting
Francesca Messini
Deloitte Luxembourg
Theory vs. Practice: Key
Requirements & Case Studies
© 2013 Deloitte Tax & Consulting 6
2012 2013 2014
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
• Starting date: on the basis of the information available so far, ESMA’s best estimate is that the registration of the first
TR is not likely to take place before August 2013 and the reporting start date depends on the actual date of the
registration of the first TR : “where there is no TR registered before or on 01 April 2013, the reporting start date is
extended to 90 days after the registration of the TR”
• Reporting start date is extended by 180 days for the reporting of information referred to data on valuation and
collateral ( Art. 3 of EU regulation 148/2013 – RTS on reporting to TR)
Contract reporting start date + 90 days
Contract reporting start date + 3 years
16 August 2012
EMIR entry into
force
23 September 2013
Reporting start date for
credit and interest rates (if
TR has registered before 1
April 2013)
1 Jan 2014
Reporting start date for all other
contracts (if TR has registered for
product type before 1 October 2013)
Tra
de R
ep
ort
ing
Historical
contracts:
Key d
ate
s
Contract reporting start date + 3 years
19 December 2012
EU Commission adopted
technical standards
15 March 2013
Entry into force of
technical standards
Contracts outstanding on 16/08/12 and still outstanding on the reporting start date:
Contracts entered into on or after 16/08/12 that are closed on reporting start date:
Contracts outstanding on 16/08/12 that are closed on reporting start date:
15 March 2013
TR application
begins
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
Source: EMIR, Deloitte Analysis
OTC Derivatives Reporting The countdown to reporting obligation
© 2013 Deloitte Tax & Consulting 7
Theory: EMIR Requirements Key requirements aiming at increase market transparency
Counterparties and
CCPs shall ensure that
the details of any
derivative contract
(OTC and ETD) they
have concluded and of
any modification or
termination of the
contract are reported to
the TR no later than
the working day
following the
conclusion,
modification or
termination of the
contract.
(Art. 9 EMIR Law)
By the end of the day
following the execution,
contract and all its
characteristics are
reported
Record keeping following
termination of the contract:
• at least 5 years for
counterparties
• At least 10 years for
TRs
If no authorized TR is in
place by 01 July 2015,
the information are
reported to ESMA
Where no contracts are
concluded, modified or
terminated, no reports
are expected, apart
from the updates to
valuations or collateral
DAILY data to report:
• Information on collateral
can be reported on a
portfolio or single
transaction basis
• Fields on the contract
valuation, as maintained
and valued by the CCP
• Changes in market-to-
market or market-to-
model valuations on
already reported
transactions (for
bilateral trades)
Intraday reporting in
NOT mandatory
Lifecycle events are
covered and a log must
be done (Art. 4 of EU No
148/2013);
All information should be
reported at the end of the
day in the state that it is in
at that point.
Source: EMIR, Deloitte Analysis
© 2013 Deloitte Tax & Consulting 8
Theory: EMIR Requirements General Reporting Fields
Source: EMIR, Deloitte Analysis
Contract Type
Details on the transaction
Modifications to the report
Risk mitig. / Reporting
Clearing
Counterparty data
Common data
Interest Rates
Foreign Exchange
Options
Common data specific
to each type of products
Commodities
• Information pertaining to the derivative transactions
executed between the two counterparties
• Common data reported must be agreed between both party
• 59 data fields split in 5 sections
• The details of the transaction are reported by Unique Trade
ID (UTI)
• The derivative product are identified by a unique product ID
(UPI), which reflects the class and type of derivative
• Reporting log for the modification of data
About it
• Information related to the counterparties to the contract
• Reported separately by each counterparty or their appointed 3rd party
• 26 data fields
• The counterparties and the other entities (such as broking entity, CCP, clearing member,
reporting entity) are identified based on a unique code (i.e. LEI)
&
&
• Specific information and fields are different from the class
of derivatives being reported
• Not required to be reported if the UPI is reported in the
Common data and contains all the information to be
reported for the specific product
© 2013 Deloitte Tax & Consulting 9
Theory: EMIR Requirements Key requirements for historical contracts
OTC Derivative and Exchange Traded
Derivative (ETD) which were still
outstanding on 16 August 2012 will have
to be reported within
• 90 days of the date of the reporting
obligation coming into force if they
are STILL outstanding on that date
• And within 3 years of the date of the
reporting obligation coming into
force if they are NOT outstanding on
that date
Requirement (Art. 5 EU 1247/2012)
Specific requirements:
• No need to report separately any life cycle events
which occurred before the reporting date
Frequency
• The contract can be reported at position level in its
final state or, for contracts which are still
outstanding, its state at the time the report is
submitted
• OTC derivatives still outstanding will need to
include the information on valuation and collateral
as from the date of the reporting obligation (and
not for all the days from 16 August 2012 to the date
of the application of the reporting)
• OTC derivatives terminated before the reporting
obligation starts applying should not include the
information on collateral and valuation
• Trade-ID
• Applies to contracts still outstanding at the time
of reporting
• need to be agreed between the two
counterparties and reported, together with the
other information on that contract
Content
1
2
Source: EMIR, Deloitte Analysis
© 2013 Deloitte Tax & Consulting 10
Theory: EMIR Requirements Roles & Responsibilities into the Reporting framework
Source: EMIR, Deloitte Analysis
Options Roles
Count A Count B
TR
2 delegation
1 Reporting by both counterparties
• Counterparty A and B reports separately to TR
• It is possible for each party to report to a different TR
• The TRs will reconcile the reported transactions via a
Unique Trade ID (UTI)
• Both parties have to ensure that common data are
consistent across both reports for the same trade
2 Reporting by one counterparty on the behalf of the other
• Counterparty B reports the Counterparty data of each party
and only one copy of the Common data
• The full set of details should still be provided by
counterparty A to B, as long as the information is available
3 Reporting by a (single / different) 3rd Party on behalf of 1
or both counterparties
• Conduct due diligence process of the reporting 3rd party
• Same liabilities and directives as the counterparties: data
protection schemes
• Voluntary delegation agreement, however the national
authority can revoke the utilisation of a third party
• Written agreement between the parties
Count A Count B
TR
3
3rd entity
A 3rd entity
B
delegation delegation
3rd entity
Count A Count B
TR A
1
TR B
ESMA
UTI
© 2013 Deloitte Tax & Consulting 11
Practices: Cases study Reporting process & roles
Transactions cleared by the CCP
Count A
Clearing
Broker /
CM
Count B
Affirmation
platform
CCP
Clearing
Broker /
CM
OTF
RFQ
Confirmations
Margins Margins
Margins Margins
Confirmation Confirmation
Trades
RFQ 1
2
Reporting
to TR
3
4
Roles
• Counterparty(s) can delegate to CCP the reporting to TR: it
can choose the TR to be used and leave the choice to the
counterparty on whether to accept or not the service for its
trades to be reported by the CCP on its behalf;
• If BOTH counterparties agree to delegate reporting to CCP,
the report should indicate that is made on behalf of both
(Counterparty data field 9);
• The CCP becomes the counterparty in the report when the
counterparty is not aware of the identity of the other;
• Avoid duplication: counterparties and CCPs should agree
on the most efficient reporting method;
• In case of different TRs, CCPs and the counterparties
should report to the TRs consistent data, including the
same trade ID and the same valuation information to be
provided by the CCP to the counterparties;
• Where clearing takes place on the same day of
execution, the report should be submitted once to a TR up
to 1 working day after the execution;
• Where clearing takes place after the day of execution
and after reporting is made, novation should be reported as
an amendment to the original report up to 1 day after the
clearing took place.
Process
Source: EMIR, Deloitte Analysis
© 2013 Deloitte Tax & Consulting 12
Cleared OTC transaction
NON - Cleared OTC transaction
Client Investment firm
(acts as principal)
Counterparty
CCP CM A
B
B
Imp
lic
ati
on
s
• The Client (FC or NFC) has the duty to report to TR 1
Case study 1 BACK to BACK transactions
A B
Practices: Cases study Reporting transaction scenarios
TR
Back-to-back
• The Investment firm, acting as principal, meaning
becoming a counterparty of the derivative
transactions, has the duty to report to TR: report the
Client as counterparty (field 3 of Counterparty data)
2 • The investment firm, acting as principal, meaning
becoming a counterparty of the derivative
transactions, has the duty to report to TR: report the
other counterparty as counterparty (field 3 of
Counterparty data)
• The Client will name the Investment firm as its
counterparty
3 • The Counterparty will name the Investment firm as its
counterparty
3
2
• The Counterparty has the duty to report to TR 1
• The Investment firm has to report the 2 trades 4
delegation
Source: EMIR, Deloitte Analysis
© 2013 Deloitte Tax & Consulting 13
Cleared OTC transaction
NON - Cleared OTC transaction
Individuals Bank
B
B
Imp
lic
ati
on
s
• Individuals are not subject to the reporting obligation
under EMIR
1
Case study 2 Individuals and Private clients
A B
TR
• The Bank has the obligation to report the trade to TR,
including the internal code of the individual with whom
it has concluded the transaction
1
Practices: Cases study Reporting transaction scenarios
A
Source: EMIR, Deloitte Analysis
© 2013 Deloitte Tax & Consulting 14
Cleared OTC transaction
NON - Cleared OTC transaction
Client
Bank
(execution of order or
receipt and
transmission of orders)
Counterparty
CCP CM A
B
B
Imp
lic
ati
on
s
Case study 3 Bank as an AGENT
A B
Source: EMIR, ESMA Q&A, Deloitte Analysis
• The Client (FC or NFC) has the duty to report to TR 1
• The Bank acts a agent (introducing broker): it means
that it does not sign or enter into any derivative
contract with the Client or the Counterparty and is
therefore not considered as counterparty under
EMIR, thus not being under the duty of reporting
2
• The Counterparty (FC or NFC) has the duty to report
to TR
1
• The Bank acts a agent (introducing broker): it means
that it does not sign or enter into any derivative
contract with the Client or the Counterparty and is
therefore not considered as counterparty under EMIR,
thus not being under the duty of reporting
2
• The Client and the Counterparty have the duty to
report, in quality of counterparties: they will know
each other as they will sign the bilateral agreement
3
• The Bank is identified as broker by the Client and by
the Counterparty in their reports (Counterparty Data -
field 8)
4
Practices: Cases study Reporting transaction scenarios
TR
delegation
REGIS-TR – the first European
Trade Repository for Derivatives
Powered by:
16
REGIS-TR
What REGIS-TR can be for the industry
A Trade Repository offering
registration and reporting services for
Derivatives out of Luxembourg
Belonging to well known European
Market Infrastructures within two
exchange infrastructures
What is REGIS-TR and who is behind REGIS-TR
Registration and reporting services for
Derivatives and holding the customer data
exclusively in the EU
Providing a one-stop-shop service, based on
a reliable, cost-efficient TR solution for all
types of market participants
Delivering added-value services well
beyond regulatory compliance – matching,
exposure management, third-country
domestic solutions…
What REGIS-TR brings to the industry
Reporting of
all asset classes
Interest rates
and fixed-
income
Equities
Foreign
exchange
Credit default
swaps
Commodities
Exchange
Trades Derivs
17
REGIS-TR
Technical architecture:
Developed on BME’s mainframe IBM platform with a central database server
using DB2
Efficiency, high security and scalability
Contingency measures:
Use of existing BME’s mainframe also used for CSD function:
Maximum back-up quality standards
Availability of two redundant locations with data centres and offices, with
synchronous data replication:
Integrity of back-up data
Internet access = BME Internet infrastructure with high capacity bandwidth and
complete redundancy: connection with two different ISPs through two
independent nodes. All components duplicated
Tested every 6 months
REGIS-TR is based on a secure and scalable system
environment
18
REGIS-TR
Market Participants
CCPs
Post-trading platforms
Clients
Trading platforms
Supervisory
Authorities
Third Party
delegation
Reporting Obligation
Information
enhancement Directly?
REGIS-TR – Reporting Flows
19
REGIS-TR
Feb 2012 Reporting flow for Reporting Participants
Reporting
Participant Counterparty
Regulator
1) Delegation
(optional)
3) Message
Accepted/Rejected
4) Reporting
5) Trade Status*
*) Trade status messages include information on contract, reconciliation and delegation statuses.
2) New Trade
5) Modifications,
Valuation/Collateral Update,
Cancellation/Termination
Seamless communication through alternative channels:
20
REGIS-TR
Feb 2012 Reporting flow for Third Parties and Non-Reporting
Entities
Third Party
Non-
Reporting
Entity
Regulator
1)
Delegation
3) Message
Accepted/Rejected
3) Trade Status*
5) Check
4) Reporting
*) Trade status messages include information on contract, reconciliation and delegation statuses.
BK (Backloading), VU (Valuation Update), VR (Valuation Received), MX (Modification), xT (Termination)
2) New
Trade
5) BK, MX,
VU, TT, FT 3) Trade Status*
Non-Member
1)
Delegation
Seamless communication through alternative channels:
21
REGIS-TR
Feb 2012 Flexible account structures accomodating needs of customers
Master Accounts – For direct
participants of REGIS-TR, allowing to
link “n” sub-accounts containing the
registered contracts (m prop and n client
accounts)
Sub-Accounts – Identified as prop or
counterparty account (n/m number of
accounts) to facilitate reconciliation and
control processes
Special accounts for trades coming from
3rd Parties and CCPs to facilitate
reconciliation and control processes
Possible activities you can have in REGIS-TR:
Reporting of own trades
Reporting of customer’s trades
Outsourcing of reporting to 3rd Parties possible
Consolidation of reporting obligation in one entity of a holding
structure
Master
Account
Participant
A
Master
Account
Participant
B
Master
Account
(3rd Party)
Prop
Direct Rep
…
Count.
Count.
…
Count.
Count.
Count.
…
Omnibu
s acc
Prop
From CCP1
Prop
From CCP2
Prop
From 3rd P1
Prop
From …
Prop
Direct Rep
…
Count.
Count.
…
Count.
Count.
Count.
…
Prop
From CCP1
Prop
From CCP2
Prop
From 3rd P1
Prop
From …
22
REGIS-TR
Feb 2012
REGIS-TR offers flexible and industry-standard access
System Access and communication
between participants and REGIS-TR:
Use of web-based application
Manual input/queries with secured
Internet access. Web access, exportable
to CSV files
Mass upload/download of XML files
through secured Internet access
Automatic transfer of XML files through a
SWIFTNet FileAct file transfer
connection and SFTP under
developement
SOAP API connection via web services
Processing of CSV files and data
transfer via SWIFT MT messaging under
development
Customer Service helpdesk during EU
working hours
Advantages:
Cost-efficient platform, accessible
from “anywhere”
Efficient/cost-effective particularly
for small participants
Efficient for medium- to large
participants
Use of low-cost widely used
industry standards
Alternative connection
possibilities, further flexibilizing the
options for participants
Online helpdesk support
Easy build-up of XML and CSV messaging that is widely used.
23
REGIS-TR
Access based on the ESMA technical standards
Access granted in accordance with regulatory demand, be it international or
domestic
REGIS-TR will record information regarding the access to data given to the
entities listed under EMIR, including the scope of data accessed and a reference
to the legal provisions granting access to such data, as ESMA technical
standards indicate
XML reporting provided by “push” to respective supervisory authority
Web based access with “supervisor” profile defined for each supervisory
authority providing:
Immediate full view of relevant entities’ positions exportable to CSV files
Pre-defined queries exportable to CSV files
Aggregated market dissemination on regular based (weekly statistics)
Archiving of information:
10 years after termination of contracts
Can be increased if required
Access for market authorities
24
REGIS-TR
Rolled-out and planned developments
Ongoing developments:
Continuous enhancement of “Final Report-compliant” permanent test environment
(Nov 2012)
Connectivity to different CCPs, starting with Eurex Clearing
Capturing of trade details of OTC- as well as Exchange-traded and cleared
derivatives directly from the clearing-house
Connectivity to SWIFT
Capturing of trade details of OTC derivatives transactions confirmed via
SWIFT MT messages directly out of the SWIFT system Value-added Services for 2013
Reporting Hub:
REGIS-TR to perform central reporting hub services for future trade reporting necessities
of the industry in the framework of e.g. MiFiD, REMIT, CRD IV…
Exposure Management:
Existing international or domestic collateral pools for collateralisation of exposures in OTC
derivatives (Clearstream Cmax)
Bilateral portfolio reconciliation services for counterparties to comply with the
reconciliation obligations defined in ESMA technical standards.
25
REGIS-TR
Added-value services with our partners
OTC Collateral Management:
Collateral agreement negotiations
CSA set-up
Exposure valuation
Margin call administration
Portfolio reconciliation
Cash/securities management
Reporting through REGIS-TR
TriOptima connection:
TriOptima offers a range of analytical tools to
support your derivative trading, including a
connection to REGIS-TR.
Portfolio reconciliation and counterparty
exposure management
Portfolio compression and early
termination
Counterparty risk balancing
Other partners include:
26
REGIS-TR
Why REGIS-TR?
Product offering:
Close contact with ESMA
First “ESMA-compliant” test environment
launched in Nov 2012. Free access
A complete technical documentation
available. Mapping works can be started
already.
Reporting can be made easily via XML
files and soon via CSV files as well
Automation of connectivity: SWIFTNet and
Web services SOAP API
Connectivity to Eurex Clearing and Meff
A number of software providers partnering:
B+S, C24, Cinovo, CAD IT…
Reporting Hub: central reporting hub
services e.g. MiFiD, REMIT, CRD IV…
Exposure Management: connection with
Clearstream Collateral management
system
Commercial offer:
One-stop-shop in the EU
Clearstream sales force coverage &
technical help-desk to assist your IT team
Flexible participation profiles, allowing any
entity to participate directly or delegate to a
third party or play both roles if necessary
Legal agreements already available
Flexible fee schedule with caps and
discounts (free Backloading before
reporting start date)
OTC derivatives reporting
Use SWIFT to comply with EMIR
17June 2013
Joe Halberstadt
How can SWIFT help?
28
EMIR
Standards for electronic confirmations
Matching & Affirmations
Reporting to Trade Repositories
Access CCPs
Consulting services
EMIR & OTC derivatives reporting - June 2013
SWIFT standards
EMIR & OTC derivatives reporting - June 2013 29
• Enhanced for OTC derivatives
– Carry additional data, like CCP information
and unique transaction identifier
– Support reporting to Trade Repositories
• Solution
– New sequence: “Reporting Information”
– Optional sequence, all fields optional
• Effective date
– For live: November 2013
– For test environment: July 2013
– Interim solution: use existing messages
with Unique Swap Identifier in field 72
Confirm electronically and timely
SWIFT Affirmations + Alliance Lite2
EMIR & OTC derivatives reporting - June 2013 30
Accord Affirmations
Alliance
Lite2
Cloud based
Low-cost, secure solution to confirm trades electronically
Easy: accept/reject with mouse click
Integrated audit trail
SWIFT solutions for derivatives reporting
EMIR & OTC derivatives reporting - June 2013 31
You Reports
(XML, FpML,
csv, …)
Automatic file transfer:
FileAct
Confirmation copy:
FINInform
Trade repository
• REGIS-TR
• LSE Unavista
• Russia, Hong Kong
• Re-use your SWIFT connection
• Cost-effective, automated file transfer
• High security: authentication, electronic
signature, encryption, non-repudiation
You
MT3xx
Trade repository
• REGIS-TR
Counterpart
• Re-use your SWIFT connection
• No need to produce report for initial
submission
• Confirmations containing trade details
are copied to trade repository
• DTCC
Global Trade
Repository
• Re-use MT300 for NDF clearing at CCPs
• Seamless copy via collaboration with MarkitServ
• Future extension to FX Options
Access CCPs via SWIFT
EMIR & OTC derivatives reporting - June 2013 32
Single SWIFT message to confirm trade,
report to repository,
submit for clearing!
See MarkitServ press release.
You Counterpart
(1) MT300 confirmation
Custodian
(6) MT304
MarkitServ
(2) Copy to
CCP Gateway
(4) Status - MT396 (3) CB Take up
Clearing broker
CCPs
(5) Submit to
CCPs
• LCH
• SGX
• CME
• HKEX
EMIR & OTC derivatives reporting - June 2013
Thank you
33
Further information
• http://www.swift.com/products_services/derivatives_overview
• Factsheets
– Standards Release 2013 - Changes for OTC derivatives
– SWIFT Accord Affirmations with Alliance Lite2
– OTC derivatives trade reporting
– MarkitServ FX Clearing Service
EMIR & OTC derivatives reporting - June 2013 34
© 2013 Deloitte Tax & Consulting 35
Q&A | Panel
• Nicolas Boatwright
• Laurent Collet
• Joe Halberstadt
• Francesca Messini
© 2013 Deloitte Tax & Consulting
Laurent Collet
Deloitte Luxembourg
What’s next: challenges &
opportunities | linking the dots
© 2013 Deloitte Tax & Consulting 37
EMIR – The journey to the compliance starts now What do you need to do ?
Source: Deloitte Analysis
1. Impact assessment – Have a clear idea of how EMIR impact you in
terms of :
• Products / volumes
• Clients (FC, NFC, NFC+, Persons)
• Counterparty – Contracts
2. Set up the right priority to compliance tasks. Align your compliance
planning in terms of tasks complexity, gap assessment, authorities timeline
3. Keep in mind the global regulatory picture. Collateral is a transversal
topic within incoming regulatory framework (AIFMD, UCITS V & VI, ESMA
Guidelines, CRD IV, …)
4. Setting up trade repository arrangements
5. Consider report directly to the trade repository or delegate reporting
to your counterparty or a third party ?
6. Identify data sources; planning around systems developments and
user-acceptance testing; consideration of data protection issues
7. The longest journey starts with a single step, but how you reach your
destination depends who walks at your side..
© 2013 Deloitte Tax & Consulting 38
Your facilitators today
42, Avenue J.F. Kennedy
L - 1855 Luxembourg
Tel: +352 243 36481
Email: [email protected]
Francesca Messini
Manager
Tel:+352 451 452 791
Mobile: +352 661 451 744
Mail: [email protected]
Laurent Collet
Director
Tel:+ 352 451 452 112
Mobile: + 352 661 451 411
Mail: [email protected]
Benjamin Collette
Partner
Tel:+ 352 451 452 809
Mobile: + 352 621 283 574
Mail: [email protected]
SWIFT
London
Tel: +44 20 7762 2129
www.swift.com
Xavier Zaegel
Partner
Tel:+ 352 451 452 748
Mobile: + 352 621 364 628
Mail: xzaegel.lu
© 2013 Deloitte Tax & Consulting 39
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