SFTR requires the reporting of all VALUEPAER financing transactions to TRs. RCs centrally collect and maintain records of SF transactions. They play a key role in improving the transparency of FTS markets and reducing risks to financial stability. As mentioned above, when conducting an FTS with a CF, an NFC does not have to submit relevant reports, as these are submitted by the CF on behalf of the NFC. However, NFC-s that do not perform FTS with a CF must submit reports. Depending on the different configurations available, Interactive Brokers customers may not run SFT with a FC, and therefore Interactive Brokers offers a delegated reporting service to ensure that its customers can report all the SFT they run. SfTR reporting obligations apply to whom: Reporting obligations generally apply to all customers established in the EU, with the exception of natural persons. They apply to transactions to be reported under the SFTR: repurchase agreements, equity loans, margin loans, sale/redemption transactions and collateral management transactions. Dentons` experienced team will be happy to help you transition to MRRA from your existing reporting contracts.

We understand that many companies may have adapted the existing reporting agreement to their internal needs, and we would be happy to help you adapt your agreements to mrra`s broader reporting capabilities. 1. There are differences between the derivatives and FTS markets. The spectrum of buy-side market participants in the derivatives market is much more diverse than in the SFT markets. In general, it could be assumed that FTS market participants have a reasonable level of sophistication and financial resources to comply with regulatory reporting obligations themselves, which may not be the case on the buy side of the derivatives market. The seller`s reluctance to accept delegation of reporting under the Securities Financing Transaction („SFTR“) Regulation is a headache for buy-side companies. If buy-side entities are unable to conclude delegation agreements, they may bear the costs and operational burden of communicating the details of the SFTs they enter into to a trade repository. ESMA has developed detailed rules and guidelines for reporting, recording and access to data.

Please read and keep the relevant procedure manual to fully understand how the hsbc SFTR delegated reporting service works and how it can help you meet your reporting obligations: As mentioned above, SFTR reports submitted by both counterparties to an FTS must contain the same UTI. To ensure that this requirement is met, Interactive Brokers offers that all its clients in the scope delegate reports to Interactive Brokers. Interactive Brokers takes care of the generation of corresponding urinary tract infections when it submits its own reports and those of its clients, on whose behalf it submits reports. For small banks and investment firms, the implementation date of the declaration is 13 April 2020. Undertakings that are unable to enter into appropriate delegation arrangements before the expiry of that period shall make arrangements to report directly to a trade repository as soon as possible. We can work with clients to determine their reporting obligations and review documentation related to their cooperation with trade repositories. The reporting requirements for SFTs will be phased in over a period of nine months from 11 April 2020. As in the case of EMIR, the dates from which firms are required to start reporting SFTs vary according to their `type of firm`, with investment firms and credit institutions being the first to comply with all SFTs concluded on or after 11 April 20206.

If one counterparty falls within the scope and the other does not fall within the scope, the reporting counterparty may need to obtain data from its counterparty and request a derogation from the confidentiality requirements to ensure that it is able to provide the appropriate information to the trade repository. While companies have already entered into agreements with their counterparties for these purposes, the MRRA contains the necessary language to achieve this. The selling party accepted the widely accepted delegation of derivatives transaction reporting under the European Market Infrastructure Regulation („EMIR“). Buy-side participants in SFT markets generally expected the sell-side approach to be adopted in terms of delegating reporting under EMIR for sfTR reporting purposes. This assumption was not unreasonable given that: The Association of Financial Markets in Europe (AFME), the Futures Industry Association (FIA), the International Capital Market Association (ICMA), the International Swaps and Derivatives Association, Inc. (ISDA) and the International Securities Lending Association (ISLA) have published a new agreement to simplify reporting in the various regulatory systems of the European Union. Background: The Securities Financing Transactions Regulation („SFTR“) is a European regulation that aims to mitigate the risk of shadow banks. SFTs were identified as one of the main causes of the financial crisis and, during and after the crisis, regulators struggled to anticipate the risks associated with securities financing.

This led to the introduction of a reporting obligation for these SFTs. In this context, it is particularly important that the world`s unique transaction identifier – a UTI – is used and shared between the parties to the transaction. The parties should agree on who should generate the urinary tract infection. In the absence of such an agreement, the regulation describes a cascading model of who would be the generating party. The generating party is required to promptly share the ITU in electronic form with the contractual partner so that both parties can comply with their T+1 reporting obligation. Reporting schedule to trade repositories: The start of reporting is July 13, 2020: July 2020: Phase 1 to 13 of the report. July 2020 Commissioning of reports for banks, investment firms and credit institutions and central counterparties and CSDs Oct 2020: Report Phase 2 – Insurance, UCITS, AIFs and pensions Jan 2021: Reporting Phase 3 – Go-Live reporting for non-financial companies You are invited to prepare a presentation to provide an overview of the structure and functioning of the Regulatory Reporting Framework Agreement (MRRA), published jointly by five interbranch organisations in December 2019 to simplify reporting arrangements in the different EU regulatory systems. This session will focus on how market participants can use the MRRA model to document and manage their regulatory obligations and provide services related to the reporting of OTC derivatives under EMIR. You will hear from legal experts on the use of ARMR in practice, both in terms of mandatory and delegated reporting of derivatives and the underlying regulatory landscape of reporting under EMIR Refit.

Buy-side companies may also raise SFT reporting issues with relevant industry bodies and/or their regulators. The key elements for the proper functioning of the reporting system under the SFTR and the assurance of the quality of the SFT reporting are (i) the validation of data transfers by RTs by TRs by COUNTERPARTIES subject to reporting obligation, (ii) reconciliation of data between TRs and (iii) response mechanisms. While the existing reporting arrangement dealt with the possibility for a derivatives counterparty to delegate its EMIR reporting obligations, EMIR Refit and sfTR require that if one of the counterparties to the transaction in question is a financial counterparty (FC) and the other party is an NFC4, the FC is responsible and legally responsible for the reporting both for itself and for its counterparty and the accuracy of ensuring the disclosure of information5 (mandatory reporting). MrRA`s modular approach allows parties to agree on different annexes (and add new ones as regulatory deadlines) to meet their requirements, whether mandatory or delegated. 12 months after the date of entry into force – Reporting obligation for credit institutions, investment firms and relevant third-country companies The MRRA establishes common conditions for the mandatory and delegated reporting of derivatives transactions under EMIR that are compatible with the amendments introduced under EMIR Refit, as well as with SFTR SFTR SFTS financing transactions. .