新的监管要求, 当前和待处理, place additional demands on firms' middle and back offices. 前进的最佳途径是什么? A holistic approach, writes Timothy Keady, Chief 客户端 Officer and Head of 存的解决方案. 有经验的第三方建议, 无论是供应商还是顾问, will allow firms to identify the optimal approach to increasing their middle- and back-office efficiencies, Keady解释说, and also ensure their 帖子-trade processes are robust and ready for the next wave of regulation.
Since 2008 financial crisis and the ensuing 2009 G20 Summit in Pittsburgh, when the decision was made by policymakers to mitigate systemic risk by strengthening market infrastructure and 帖子-trade processes, the industry has faced waves of new and revised regulations and has adapted to meet evolving compliance requirements. And their efforts continue as forthcoming regulatory changes over the next two years include the push toward harmonizing derivatives trade reporting standards across jurisdictions, the implementation of the final phases of uncleared margin rules (UMR) and the start of CSDR’s 结算 Discipline Regime (SDR).
结合现有法规, these and other emerging mandates are significantly straining firms’ operations. Given most infrastructure and control frameworks at individual companies are already a patchwork of functionalities assembled over a decade of adapting to regulatory change, they now face a number of challenges including when to upgrade infrastructure to comply with forthcoming regulations, how regulatory obligations can be fulfilled in a manageable and cost efficient way and how to ensure these upgrades can future-proof a firm for ongoing regulatory change in an environment that may include more rigorous enforcement.
When considering how to approach these important decisions, 我们可以看看房主的例子, 谁, 搬进来已经20年了, is faced with an outdated kitchen and old appliances. Incremental or do-it-yourself (DIY) repairs may appear easy and cheap at first glance, but they could fail to pass inspection and may delay the inevitable full renovation that’s required.
When you combine this regulatory landscape with decades old processes, 控制, 治理和系统, solving for these compliance challenges may seem overwhelming.
类似的, while a piecemeal or DIY approach to adapting to regulatory change may be less daunting in the short-term, it will likely be more costly and onerous in the mid to long term. 在理想的情况下, 当涉及到运营基础设施时, 控制和过程, firms should address upgrades in a holistic way that delivers the greatest value and readies them for regulatory changes in the short-term and beyond.
长长的待办事项清单
The current and forthcoming regulations around transaction reporting, UMR and settlement discipline across multiple jurisdictions are significant. 监管措施, like the CFTC and SEC’s planned expansion and potential reengineering of the trade reporting construct laid out in 2013, along with more rigorous requirements around liquidity management and settlement for UMR and CSDR, 分别, will require continued changes to firms’ compliance strategies and processes
When you combine this regulatory landscape with decades old processes, 控制, 治理和系统, solving for these compliance challenges may seem overwhelming. 为了跟上节奏, firms must simplify their trade reporting data sets, become more sophisticated in sourcing key data elements related to collateral and unique identifiers, ensure a robust and automated collateral management workflow and implement measures to further mitigate settlement fails.
最优方法
By focusing on key areas of the 帖子-trade process and taking advice and considering proven offerings from third parties with experience in these areas, 比如咨询师, 供应商或市场基础设施, market participants can identify the optimal approach to reconfiguring middle and back office operations to ensure their 帖子-trade processes are sufficiently robust and future-proofed for evolving regulatory mandates. 衍生品交易报告, operations teams need to account for new data fields, 新vnsr威尼斯城官网登入, 新的流程和控制, 新的利益相关者. UMR requires heightened monitoring and control of liquidity and SDR requires more-efficient settlement processes that drive down fails.
The optimal approach for market participants is to view this demanding compliance environment as an opportunity to transform legacy systems and processes for trade reporting, liquidity management and settlement for the long term — simplifying and modernizing them to meet new and evolving global regulations while leveraging best practices. 这样做的时候, firms can achieve a scalable and efficient infrastructure that lowers operating costs and risk, meets evolving mandates and positions them for future operational and business success.
This article first appeared in TABB Forum on June 4, 2021.