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Abide Financial Limited EMIR Reporting Services May 2013. Contents. EMIR status update Requirements Update on timelines Implementation challenges Abide EMIR Reporting Services Abide positioning High Level System Architecture Service description overview
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Contents • EMIR status update • Requirements • Update on timelines • Implementation challenges • Abide EMIR Reporting Services • Abide positioning • High Level System Architecture • Service description overview • Implementation preparation for Abide Customers • Abide Reporting Service
EMIR TR Reporting Summary • All derivative transactions, their termination or modification, whether OTC or Exchange-Traded, are reportable • Once per day update on collateral and Mark to Market to be reported per trade • There is no lower value threshold • There are no exclusions for FX, Commodities, Interest-Rate or Index-related derivatives • Transactions should be reconciled between the counterparties before reporting by T+1 • Both counterparties report Counterparty Data Set (26 fields), only one needs to report Common Data Set of trade details (59 fields)
EMIR Timeline (As at May 2013) Within 90 days Within 3 years
EMIR Implementation Challenges No mechanism for data validation by TRs in EMIR No EMIR data extraction and enrichment tools widely available Data standards (LEI, UTI, UPI etc) will not be ready in time for initial implementation – interim solutions are required EMIR designed initially for OTC transactions – ETDs are an after-thought Standards and operating procedures for managing interchanges, including reconciliations, between TRs are not defined The operational model and reporting responsibilities between reporting firms, TRs and CCPs is in its infancy The day one legislation will continue to be refined as issues present themselves
Positioning • Abide believes in the first instance, we can secure better value for our clients by using another repository for the utility reporting aspects • Abide will continue to invest in the core service that differentiates us today • Single data ingestion – multiple regulatory and non regulatory services • Data enrichment and aggregation • Enhanced validations • Standard and customised reconciliations on offer • Outputs to selected authorities in multiple formats • Targeted advisory services • High levels of service management • Abide continues to review landscape. At the appropriate time, Abide will become a repository
Abide’s Regulatory Reporting Service Reporting Firm Reporting , Reconciliation and Exception Management Reports produced for MiFID Abide Hub & Value Added Services FSA Abide ARM Reports produced for EMIR ESMA Abide EMIR Reporting TRUtility PublicAccess
Abide Platform Architecture Source handler metadata Business logic metadata Output / display metadata ARM I n g e s t o r JSON records V a l i d a t o r F S H a n d l e r FTT JSON records ARM DB JSON records JSON records TR FTT DB JSON records JSON records TR DB Other Table storage Data sources RDB storage Security GUI
EMIR Trade Reporting Core Service Description • Combined MiFID and EMIR reporting • Data ingestion and validation • Apply a number of basic, logic-driven and reference data driven validations to data reported to trade repository • Back-load of data to August 2012 • Operational monitoring and management • Event-driven notifications of exceptions and errors • System processing status reports • Maintain comprehensive log of all additions and changes • Reconciliation • Against source data, clearing dataand data held in the TR • Implementation support for Trade Reporting responsibility definition • e.g. delineation of reporting responsibilities between trade flow participants • Preparation of data for publication in the Trade Repository
EMIR - Implementation Service Options • Identifying trade flows and reporting responsibilities • Data acquisition • Data sources, semantic gap analysis • Data validation and enrichment • Development of operating model • Integration with existing operational processes and data formats • Management Information content and delivery mechanism • Exception management and service management configuration • Development of interim solutions to counter EMIR issues • UTI matching, LEI & UPI workarounds • Bespoke reconciliation & reporting • Multi way reconciliation designed to customer requirements • Inter TR reconciliation • Management information and reporting designed to customer requirements • Position reporting management & updates; complete flexibility on data formats
Preparation for EMIR Reporting • Significant effort should now be focused on defining the internal business, process and system changes needed to meet the technical specifications for the EMIR reporting architecture. • Building and testing the new reporting solution – ensure capture of the 85 EMIR fields. • Updating BAU procedures to ensure capture of new data items (such as MTM of collateral, confirmation time stamps etc). • Design and implement a control framework around the new EMIR reporting process and requirements. • Back-load any trades which were outstanding on 16th August 2012 and are still open • Test the new reporting solutions (i.e. run test data through validations and into a TR)
Abide Benefits - USP • Dual reporting to the most appropriate repository • Independent, no exchange tie or influences • Multiple services possible driven from single data source • One of the few firms that can apply ARM experience to EMIR • The tailored approach to the deployed service will be expanded • Abide will isolate Clients from expected changes to regulations post regulation launch • Our advisory service will be available to help practically interpret the new regulations
For more information or an informal discussion about your EMIR, MiFID or Dodd Franks reporting requirements please contact: Chris Bates on + 44 (0) 20 7148 0971 Or send an email to: info@abide-financial.com and we will contact you.