ASSONIME 16 th July 2015

Transcription

1 ASSONIME 16 th July 2015

2 Agenda 1. EMIR reporting landscape 2. Roadmap 3. Data reconciliation 4. European reporting landscape 5. REMIT 2

3 in the European reporting landscape 16 Months of reporting Objetive: Data quality Level 1 validations Fairly modest scope Not significant effect on reconciliation and data quality LEI Successful efforts No central source yet Level 2 validations More ambitious Increase data quality No impact on reconciliation UTI Remains unsolved Main issue for pairing Expecting an European solution by year end New ESMA RTS Great impact ETDs reporting tailor-made rules UPI ESMA leading works TRs in favor of a partial solution Main issue for reconciliation 3 3

4 in the European reporting landscape Level 2 Validations MiFIR and MiFID II ESMA manages TRs roadmaps ESMA pressure on TRs increases First ESMA audit passed October 2015 Summer 2016 January 2017 Around 40 regulators onboarded. All European Historical reconciliation still a priority for ESMA New ESMA RTS Only 18 months to solve all EMIR-related issues Still very unclear guidance on reporting of specific products (CfDs, FX Forwards, FX swaps) European commission assessing the EMIR impact and unintended consequences 4

5 Agenda 1. EMIR reporting landscape 2. Roadmap 3. Data reconciliation 4. European reporting landscape 5. REMIT 5

6 Review of latest developments UTI and LEI Validations OCT NOV DEC JAN FEB MAR APR MAY JUN Level I Validations (R001) RO10 Enhanced Processing (including Level I Validations) Level I Rejection Statistics for Regulators ETD Trades Inter-TR Reconciliation News Section in the Private Area R010 Searches Historical VU & CU Reporting 6

7 Roadmap Harmonisation of Intra and Inter-TR reconciliation JUL AUG SEP OCT NOV DEC JAN FEB MAR APR JUN JUL Reconciliation Status Report Level II Validations Enhancements to Regulators Portal Public Data Single Access to TRs Project Revised Technical Standards Other developments pending on timeslot Changes to the database (TR question 25) Search Funtionality for Third Parties Super User Functionality 7

8 Agenda 1. EMIR reporting landscape 2. Roadmap 3. Data reconciliation 4. European reporting landscape 5. REMIT 8

9 UTIs breakdown Daily ~UTIs reported 6,334,841 Daily ~ messages processed 12,963,388 9

10 Reconciliation in numbers This Group of trades are not reconciled. 10

11 Reconciliation in numbers All Dual Sided are paired ~88%-90% RECO status internal Inter-TR: LEI 1 + LEI 2 + UTI + Non-EEA= N UTI issues: LEI 1 + LEI 2 UTI 11

12 Reconciliation in numbers 1. DTCC ~ 62% 2. UV~27% 3. ICE TV~10% 4. CME~1% 5. KDPW<1% OTC Pairing ETD Matching OTC ETD 12

13 Reconciliation 13

14 Agenda 1. EMIR reporting landscape 2. Roadmap 3. Data reconciliation 4. European reporting landscape 5. REMIT 14

15 European reporting landscape: timeline Upcoming regulations to be implemented (Expected Reporting Start Dates) Oct 2015 Apr 2016 Mid-End 2016! 3 Jan. 2017! Mid REMIT Phase I REMIT Phase II FinfraG MiFID II / MiFIR SFTR REMIT, MiFIR & MiFID II, SFTR, FinfraG less than 2 years to establish the reporting on the different products and regulations Some reporting overlaps (EMIR-REMIT, EMIR-MiFIR, EMIR-FinfraG) It is key to rely on a single provider based on same technical specifications (formats, connectivity, flows ) and functionality for all regulations. Complex monitoring of the different reporting if not aggregated 15

16 strategy as Reporting hub Current and future regulatory developments across European (MiFID II, EMIR, SFT, REMIT, etc.) and non-eu jurisdictions (Switzerland, Canada, Asia etc.) will dramatically impact clients operations, leading to new market needs and service offering expectations Client Data Evolving client needs (Buy and Sell side) Integrate regulatory updates in current organisation and operations Be compliant with new regulations on time Manage risk associated with connections, formatting and validating raw data Manage reporting of total volume of information Data enrichment Data input Data sourcing Full Reporting Solution Report preparation Market expectations Market participants ask for new and innovative regulatory reporting solutions which act as a one-stop-shop, minimizing client effort and supporting them in their reporting compliance on a multijurisdictional and regulatory basis: Data formatting Data validation TR/ARM/RRM Reconciliation Exception Management Third party One single connection receiving and extracting client data in different forms coming from different sources One single user-friendly GUI- interface giving an consolidated overview of clients reporting statuses as well as detailed statuses per regulation Other TR/ARM/ RRM One single central hub for managing data One single account owner One single platform ensuring timely and accurate data submission to the relevant authorities across multiple jurisdictions in accordance with regulators technical standards EMIR report REMIT report MiFIR report Trade reporting FinfraG report On demand SFT report report Key added value will be delivered by supporting the client throughout all steps of the value chain including pre and post trade reporting Competent authorities: ESMA, ACER s ARIS, Local & Foreign Regulators etc. 16

17 Agenda 1. EMIR reporting landscape 2. Roadmap 3. Data reconciliation 4. European reporting landscape 5. REMIT 17

18 About Market neutral central trade repository (TR) for derivatives transactions across multiple product classes, open to financial and non-financial institutions and servicing all types of derivative contracts in a unique market offering A pre-eminent ESMA approved European TR for EMIR aspiring to become a one-stop-shop for the registration of the full range of derivatives regulatory reporting and now widening its product offering to REMIT reporting Strong expertise in energy derivatives regulatory reporting, processing significant energy commodity volume and accounting for one of the highest participation rates in the market Major European energy exchanges within s parent group, including EEX and its member companies The first TR to be actively involved in the ACER pilot project Recent release of a detailed guide to reporting commodities under EMIR in consultation with some of Europe s leading energy participants, highlighting useful links to the EMIR-REMIT double reporting aspect Active in regulatory working groups and consultations to ensure high standard value propositions 1,232 individual client accounts reporting on EMIR with over 4bn reported trades since Feb clients reporting derivatives on Natural Gas and Power Strong client relationship management from over 40 Relationship Managers of Clearstream Core Products and Iberclear Dedicated technical helpdesk support 18

19 REMIT 19

20 REMIT: a fragmented reporting landscape 7 Oct April 2016 INCREASING FRAGMENTATION Start of transaction reporting of standardised contracts traded on OMPs Start of transaction reporting of outside OMP traded reportable contracts Client Client OMP OMP OMP Most trade on multiple OMPs: difficult to meet regulatory reporting requirements efficiently Bilateral Bilateral OMP OMP OMP trade trade Additional reporting of non-standardised contracts traded on a bilateral basis: an even more fragmented reporting landscape Reporting data across multiple OMPs increases complexity in terms of: Data management (handling data in different formats) Data monitoring across multiple reporting relations Regulatory compliance Delegation to OMPs does not imply the delegation of responsibilities. Clients remain responsible for the reporting produced One OMP acting as a single point of consolidation is not optimal either because: Market participants do not feel comfortable sending all their strategically sensitive data traded across multiple OMPs to a single OMP Reportable data such as lifecycle events and modifications may not be taken into account OMPs are not considered a natural home for reporting non-standardised contracts traded on bilateral basis 20

21 s REMIT Reporting Service Participants can use directly or through delegation to one or more OMPs Connectivity/ Data gathering Enhancement and treatment of data Exchange Management with ARIS EMIR DDBB Reporting messages REMIT DDBB Reporting messages SFTP Integrate multiple data sources and reporting format SFTP Web Portal Web Service Choose amongst the most flexible suite of connectivity channels Normalize data Validate data with required information and format Timely submission of transaction reports to ACER Web Portal Web Service DB Dashboard with reporting status Exception handling Market participants can access accepted and rejected messages (ACK/NACK) from ACER related to reported items Receipt will be issued by ACER to the reporting party to confirm acceptance/rejection of the submitted file 21

22 REMIT 22

23 REMIT 23

24 Fee schedule User profile Reporting Participants Reporting Third Parties Licence fee 350 / month (*) 0 Trade allowance 100 trades / month N/A Fee per trade above threshold 0,05 0 Order allowance 1000 orders / month N/A Fee per order above threshold 0,02 0 (*) Family groups: Entities acting as Internal Third Parties reporting on behalf of other family members will be charged 350 / month. Other entities within the family group will be charged 100 / month. We ensure full transparency of our pricing structure. Being a registered trade repository by ESMA, we guarantee no price bundling for our different product lines as well as no discretionary pricing among clients We strongly encourage market participants to look closely at all Registered Reporting Mechanism s (RRM) pricing tariffs in order to get a clear understanding of the real cost

25 Contact details 42, Avenue J.F. Kennedy L Luxembourg Tel: onboarding@regis-tr.com 25