The complete list is available in Table 2 of the First Schedule of Annex D to the reporting guidelines where MAS includes information on acceptable values and which fields apply to each asset class.Įvent and Action Types – Among the additional fields being introduced is Event Type and Event Type Date. Altogether, there are now 134 reportable fields. Along with the UPI, MAS stated that it will continue to require other product related fields such as instrument type that can be derived back from the UPI, but will re-evaluate their obligation in the future.Įxpanded Reporting Fields – Part of the harmonization process across global regulation is the move to use derivative industry endorsed critical data elements (CDE). Managed by ANNA DSB, the UPI is more granular than a CFI Code and provides more detailed information on the type of derivative product being traded. Unique Product Identifier (UPI) – Based on positive feedback from respondents to the Consultation Paper, MAS is including the UPI among new reporting fields. This replaces the current availability of CSV or fPML formats that the DTCC TR (currently the only licensed TR for MAS reporting) supports. ISO 20022 XML format – Similar to standards being implemented in the US, Europe, UK, Japan and Australia, Singapore derivative reporting submissions to trade repositories (TR) will be in the ISO 20022 XML format. MAS will also continue to apply the T+2 format that currently exists of which firms have until the end of the second business day to report new and modified transactions. Despite initial discussions of a two-phase approach for various parts of the new regulation, MAS has elected to move forward with a single new format that will be required for submissions in October 2024. Timelines – Aligning with timelines in Australia, the reporting update is set to go live in October 2024. (Learn more about Cappitech’s UTI Connect initiative for solving for global UTI generating and receiving challenges) Taking into account difficulties with sharing UTIs in time, the MAS guidelines provide firms with the ability to use a temporary UTI in cases where they haven’t received the UTI in time and to rereport with the correct UTI within two business days of getting the correct UTI. Cross-jurisdiction trades take into account which counterparty has the earliest obligation to report. For pure bilateral uncleared OTC trades, a bilateral agreement is used to determine the generator. Responsibility for creation of the UTI is per a waterfall approach based on a hierarchy of systems such as whether a CCP, Clearing Member, trading venue or confirmation platform were counterparties or part of the trade. Unique Trade Identifier (UTI) Waterfall & Counterparty Matching– Part of the update is the adoption of a single UTI to be used by each counterparty for each derivate transaction. It follows the overall trend of derivative reporting updates taking place across the globe where regulators are harmonizing much of the data required to be reported in order to improve the overall quality submitted. The release clarified certain points of the update such as timelines, reportable fields, submission formats and unique transaction identifier (UTI) generation. Advancing changes to OTC Derivative Reporting, the Monetary Authority of Singapore (MAS) last week released responses to their Consultation Paper and updated Reporting Guidelines on amendments to the regulation ( link).
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