2020年是充满意外的一年. As firms navigate record market volatility and adapt to new ways of working and delivering value, they’re now being forced to turn their attention to another historic challenge: Brexit.
The effects of the UK’s split with the European Union will be felt not only by firms, 但是他们的客户, too. Fully understanding the changes – and the steps you can take to prepare for them – is key to reducing the impact this transition will have on your operating models. 这包括贸易报告.
你可能已经知道了, 英国于1月31日脱离欧盟, 2020年又进入了过渡期, 定于12月31日结束, 2020年11点.m. GMT. 正如我们一直提醒客户的那样, the reporting obligation for UK European Market Infrastructure Regulation (UK-EMIR) and UK Securities Financing Transaction Regulation (UK-SFTR) will come into force at that time.
DTCC will offer end-to-end trade reporting solutions in both the UK and EU post-transition. 12月31日之后, 2020, firms using DTCC’s Global Trade 存储库 service (GTR) to report to the European Securities Markets Authority (ESMA) for EMIR or SFTR compliance will need to be onboarded and be ready to report to DTCC Data 存储库 (Ireland) PLC (DDRIE, 我们在爱尔兰的欧盟27国贸易仓库). In order to report to the Financial Conduct Authority (FCA) for EMIR and SFTR post-transition, clients will need to be onboarded to DTCC Derivatives 存储库 PLC (DDRL, 我们的英国贸易资料库).
我们如何提供帮助
Preparing for a smooth and successful Brexit transition may mean enhancing your infrastructure, updating some of your business processes and/or making other improvements to your post-trade processing. DTCC咨询服务, 我们的新咨询服务, can assess the issues your firm should address to be Brexit-ready. Our consulting team then can provide tailored guidance and recommendations designed to lower the risks and costs of meeting your regulatory requirements in the post-transition environment.
Our Brexit checklist is another non-exhaustive tool to aid your preparations for the transition. This to-do list can help you assess the list of tasks your firm may need to undertake in preparation for Brexit, 当你适应新环境的时候.
Brexit清单
资格
- Determine the reporting eligibility of your entities and any entities you report on behalf of 新员工培训
- Onboard your organization and all relevant entities to the trade repositories they’ll report to post-Brexit
- If you onboarded prior to the previous Brexit deadlines, confirm your setup is up to date and accurately reflects any changes to entity structure that may have occurred in the interim
委托的报告
- Determine whether Brexit impacts your offering or usage of a delegated reporting service
强制性委托报告
- Track whether Brexit will change your mandatory delegation requirements under EMIR
- Track whether Brexit will change your mandatory delegation requirements under SFTR (For example, the FCA does not require SFTR reporting by NFC firms post-Brexit)
明确的权限
- Ensure your 明确的权限 to report for other entities under UK EMIR & SFTR已经就位
- Determine whether these 明确的权限 vary for ongoing FCA and ESMA reporting
连接
- Establish and test the ability to send/direct submissions to different trade repositories
- Establish and test the ability to consume responses and reports separately from UK and/or EU trade repositories
贸易储存库之间/内部对账
- 评估拆分EMIR的影响 & SFTR trade repository reconciliations into separate UK & 欧盟对账
- 如果适用的话, assess the impact of cross-jurisdictional reporting on your internal reconciliation controls
控制框架
- Gauge the impact on any of your “over reporting” and “under reporting” controls
- Consider potential impacts to your data quality controls and monitoring
数据传输 & 参考数据
- Assess impacts on your data feeds and reference data sources CRDE / CRD数据
CRDE / CRD数据
- Update the data held in DTCC’s Counterparty 参考数据 and Enrichment Service (CRDE) or Counterparty 参考数据 (CRD) utilities as needed
操作的影响
- Review impacts on your workflows and exceptions tracking processes
- Delegate FCA and ESMA reporting to the same or separate teams as appropriate
唯一贸易标识符(UTI)生成 & 消费
- Gauge impacts on your workflows for generating, disseminating and consuming UTI’s
规则分歧 & Schemas
- 为FCA之间的潜在分歧做好准备 & ESMA的规则是随时间变化的
- Prepare for potential divergence between ISO20022 schemas over time
Vendors & 中间件
- Monitor impacts on services or integrations with market vendors or middleware
As the go-live of Brexit-era trade reporting rapidly approaches, DTCC is here to support you in managing this regulatory change -- through our dedicated client forums, 用户验收测试会议, 咨询服务, 我们丰富的客户学习vns6060威尼斯城官网, and our relationship managers available to answer your questions. Please reach out to one of our experts today to learn how we can help: 联系我们.
请访问 lgmobilereg.com/brexit for more information on how DTCC is helping our clients prepare for Brexit.