Published: November 14, 2023
The Monetary Authority of Singapore (MAS) is introducing some notable amendments to their OTC derivative transaction reporting in October 2024. This broadly aligns with the ASIC Rewrite timelines, which we discussed previously. These changes are being introduced to enhance transparency, mitigate risk and help secure the reliability of Singapore’s OTC derivative market; whilst also simplifying reporting through standardisation and harmonisation of critical data elements across global reporting regimes.
Are you preparing to be ready for these changes? First Derivative is happy to highlight some of the looming changes to help you to stay ahead.
The table below highlights some of high-level changes that are coming in and how these align across some of the other regulations.
|Theme||MAS Rewrite||ASIC Rewrite||EMIR Refit||Comments|
|Global UTI||All align to Global UTI standards, but with differing interpretations on approach to be taken where a UTI is not shared by the reporting deadline. See further information below regarding MAS interpretation.|
|UPI||All align to Global UPI standards. ANNA-DSB is the sole service provider.|
|ISO 20022||All adopt the XML messaging format.|
|Field Changes||MAS – Reportable fields expand to 134
ASIC – Reportable fields expand to 143
EMIR – Reportable fields expand to 203
|LCE/Action Types||All introduce Event Type alongside Action Type.|
|Package/Complex Trades||MAS and ASIC introduce a “swap link ID” to report swap components as separate transactions, contrary to EMIR which requires one single contract to be reported. Package Identifier is introduced.|
|Collaterial/Margin||All regimes introduce new collateral fields to be reported.|
|Historical Backloading||MAS requires HBL upon go-live date (see further information below). EMIR REFIT allows a 6-month window. ASIC also allows a 6-month window (with various caveats as to what brings a trade in-scope).|
|Exemptions||MAS brings in exemptions for collateral reporting, whilst ASIC brings in the concept of “small-scale buy-side” entities. See further details on MAS exemptions for collateral below.|
|Reporting Deadline||T+2||T+2 Vanilla
T+4 – Structured
|T+1||APAC regulations have longer submission deadlines to allow more time for UTI sharing.|
|No Regulatory Impact|
NB: HKMA is targeting to publish its consultation by 2023-end. It has not made any regulatory announcement on regulatory timelines
MAS has introduced numerous changes to the ‘unique transaction identifier’ (UTI) and looks to embrace its use as part of the industry-wide rollout for the uniform use of UTI.
The table below showcases MAS’s rule changes.
Notably, MAS are allowing the use of an ‘Interim UTI’ where a UTI cannot be retrieved from the generating party by the T+2 deadline. This differs to EMIR REFIT, where ESMA have alluded that rather than using an incorrect or interim UTI, they would prefer no report be sent.
MAS does not expect collateral and margin details to be reported when:
MAS will require the re-reporting of all outstanding contracts in the updated reporting criteria upon compliance date. They have specified an exemption for contracts maturing within 6 months of that date. MAS also excludes the reporting of any data mandated by the new requirements that was not originally captured when the contract was executed.
This differs from EMIR where ESMA allows 180 days for historical backloading to take place and does not apply any the exemptions. Finally, contract modifications must be reported in the new format within 2 business days of the revised rules going live.
Staying ahead of regulatory changes is vital for ensuring compliance with a constantly changing regulatory landscape. Whilst challenging, this also presents an opportunity to improve overall operational effectiveness and will help to strengthen resilience to risk.
Prevalent challenges experienced across the industry include the following (though not limited to):
Will the UTI generator share the UTI in time for reporting?
Have the complex changes for this transition to XML been explored?
Has a common data model been considered across all regulations which factors in overlapping data points?
Many of these challenges are in sync with the problems our consultants have helped organisations overcome for recent regulatory changes such as CFTC Rewrite and EMIR Refit.
Our highly skilled consultants at First Derivative can help you with regulation interpretation,
implementation and support you with overcoming your regulatory obstacles. We provide impressive expertise in many areas such as PM, PMO, BA and QA and would endeavour to lighten your load and help you on the road to success. First Derivative is ready and waiting for your call.