监管 reforms are headed in the right direction to provide greater transparency in an otherwise opaque derivatives global market. 但现在, 12 years after the regulatory measures were determined at the G20 Summit, are we able to generate valuable insights from the reported data? 不幸的是，不完全是.
This gap explains the influx of revisions to trade reporting rules that will be enforced globally in the next few years to ensure consistency and standardization in data collection and reporting format to yield data, which provides insightful analysis for risk identification and monitoring.
Related: The Journey to Global Data Harmonization in Trade Reporting
目前, 亚太(APAC)地区的监管机构, which includes the Australian Securities and Investments Commission (ASIC), Monetary Authority of Singapore (MAS) and Hong Kong Monetary Authority (HKMA), are deliberating on the data sets including identifiers and other trade reporting elements with an aim to align with other jurisdictions’ regulatory rewrites and produce a more consistent data set to better detect interconnected risk.
帮助公司应对这些拟议的变化, 我和尼古拉·巴里一起参加了一个虚拟活动, ANZ Bank Head of 监管 Management; Bruce Perry, 巴克莱银行董事总经理, 营运主管, 亚太地区; and Xiangjing Ng, ISDA导演, 公共政策, 亚太地区.
如果你错过了会议，你可以 点击这里注册观看重播. 讨论内容摘要如下:
调整实施日期
As the go-live date of the regulatory rewrites varies across jurisdictions globally – between 2022 and 2024 – firms will have to adjust their reporting processes and accommodate differing implementation timelines given that OTC derivatives trades are often reportable in multiple jurisdictions.
As critical data elements (CDE) and identifiers including unique product identifiers (UPIs), unique transaction identifiers (UTIs) and legal entity identifiers (LEIs) – recommended by CPMI IOSCO1 working group on harmonization (Harmonization Group) – are increasingly being adopted in the regulatory revisions to enable global aggregation and analysis of reported data, there should be a synchronized path to implement these standards globally. This will reduce confusion and unnecessary costs to reporting entities. While the preferred option is to go for a single implementation vis-à-vis a staggered launch, regulatory bodies in APAC often take a concerted effort when administering regulatory changes, 增强地区凝聚力和协同效应.
为监管更新做准备
在接下来的几个月, firms will have to review changes stipulated by major regimes worldwide and work within a squeezed timeframe. Our panel recommended that firms first undertake a gap analysis on the reportable data and new trade data elements to be adopted. 在跨司法管辖区层面, it needs to be determined if data definitions are aligned and if they follow the CPMI IOSCO guidance. If there are any doubts in the interpretation of definitions, firms should seek clarity through industry working groups to ensure the correct data capture.
We also agreed that counterparties should be educated on new data elements like UPI, 将包含在修订中的UTI和LEI. Regulators in APAC presently allowed the use of alternative identifiers such as AVOX ID or SWIFT BIC code in place of LEI in a transaction.
以满足新的监管要求, 时间是, 当然, needed to enhance existing systems or overhaul processes – onboarding, 贸易预订, 交易确认, 通过数据协调进行边缘计算. As the key driver for the regulatory updates is data quality, internal controls must be put in place or enhanced to validate data accuracy. We believe that it is the right time to holistically evaluate and establish a scalable framework for ongoing compliance.
积分不同的点
While the regulatory revisions proposed by the respective regulatory bodies represent a remarkable improvement in the consistency of data to be reported, DTCC’s in-depth analysis revealed that there are cross jurisdictional deviations on the adoption of CDEs, 因此阻碍了全球的聚合.
In the absence of a completely harmonized set of reporting data, it is critical that firms look to design and build a flexible solution that can accommodate different data requirements – leveraging data analytics tools to mitigate operational risk.
管理不断变化的监管环境
Finally, it was stressed that we need to invest in data to draw value from data-based insights. Data will inform the way forward – getting upstream data right will ensure the correct course of action or decision be taken downstream. 通过将数据与正确的工具集成, 公司不仅能够察觉, correct and prevent potential issues but will also be able to produce accurate and clean data to strategically meet future trade reporting requirements.
1 CPMI IOSCO1: Committee on Payments and Market Infrastructures (CPMI) and the Board of the 国际 Organization of Securities Commissions (IOSCO)