Trade reporting has gotten baked into the routine for many firms across the buy- and sell-sides since over-the-counter (OTC) derivatives reporting mandates started taking effect in 2012. Firms have mastered new protocols for data collection and connected with licensed trade repositories (TRs) for report submissions. So why the surge of concern around the latest trade reporting regime? 不要过于简单化，但它归结为一件事:数据.
Europe’s Securities Financing Transactions Regulation (SFTR) imposes data requirements that are far more numerous and complex than what must be provided to TRs for derivatives transactions. And once the Central Securities Depositories Regulation’s (CSDR’s) settlement discipline regime is layered on top of SFTR, 行业的数据来源, 增强和和解的挑战将更加复杂. While the data is not difficult for TRs to process, the demands on firms are significant.
But there is some good news: synergies can be found in some emerging compliance solutions.
企业面临的4个挑战
许多事情使SFTR令人烦恼. 我听到的是:
1. Topping the list is the quantity -- depending on transaction type, as many as 155 data fields -- and quality of data elements that must be reported and reconciled. Clients tell me this breadth of information feels overwhelming, especially since a number of them aren’t currently set up to capture all the specified data elements or capture the data in the specified way.
2. A related issue is the high level of data accuracy required to match and reconcile a large number of data elements. Reconciliation presents a struggle that has not been efficiently resolved in data reporting today. SFTR的这一方面也让我的客户感到担忧.
3. 鉴于证券融资的性质, another difficulty firms may have with SFTR is extracting reportable data from the multiple internal silos and systems where it resides -- which in turn will complicate the task of submitting timely and accurate records to a TR.
4. 然后加上新数据, 比如通用事务标识符(uti), 必须生成以符合规定. 在SFTR, each securities financing transaction must have its own UTI and reporting parties must use legal entity identifiers (LEIs) to identify their counterparties, 代理银行, 中央证券存管处, central counterparties (CCPs) and other entities involved in the transaction. Please note that ESMA is allowing a period of up to twelve months starting from the July 13 implementation date during which the reports without the LEI of third-country issuers of securities which are lent, 在担保贷款中借入或作为抵押品提供的贷款将被接受.
Bottom line: SFTR’s heavy data demands will translate into lots of pre-reporting and reconciliation work by affected firms.
最好的解决方案是什么?
不幸的是, many firms lack the in-house systems (or the resources to build them) that can tackle SFTR’s new and unique data challenges in a streamlined, 自动化的方式. Even for large, well-equipped dealers, managing SFTR compliance is difficult.
幸运的是, vendors have responded to demand and created solutions to deliver the key compliance features and capabilities firms need.
在前端, before firms submit transactions to a TR: UTIs need to be generated; data files from myriad sources normalized, standardized and enriched to populate key fields; submissions pre-validated; and trades paired as part of SFTR reconciliation.
On the back end, any rejected submissions need to be tagged, repaired and resubmitted. And end-of-day trade reports must be reconciled with a firm’s internal books and records.
理想的解决方案可能是一站式服务, a toolbox of functions for any and all of these SFTR requirements that avoids bifurcated processes from the use of multiple vendors. 作为奖励, the user could add tools that help reduce trade breaks and fails in line with CSDR’s settlement discipline rules.
例如, firms can use the multi-function DTCC报告中心™ for SFTR pre- and post-reporting tasks, 定制其功能以满足他们的特定需求. 获得实际的SFTR协助, DTCC 咨询服务 will soon be available to help diagnose issues, suggest opportunities to optimize a client’s trade reporting operations and recommend improvements to other areas of a client’s post-trade processes. The DTCC报告中心™ and the DTCC 咨询服务 create a neat package for addressing various reporting needs. 除了, DTCC’s Global Trade 存储库 service (GTR) provides a licensed trade repository for SFTR reporting.
面对今天的数据驱动的法规, solutions providers should be scoping out new ways to maximize benefit for their clients. 在DTCC的案例中, 我们正在探索我们的CTM™平台, 已经产生uti了吗, can use matching to help with trade pairing for SFTR reconciliation and how our DTCC Exception Manager (DXM) could assist with exception resolution by showing SFTR transaction breaks, 这也有助于解决贸易失败.
The costs and complexity of compliance are sure to keep rising in the years ahead. 在这种情况下, efficient solutions to manage data demands will be key to meeting the challenges firms are certain to face.