Regulatory Reporting

What is common?

  • The reporting is submitted to a licensed Repository;
  • Reporting obligations are binding for all counterparties;
  • Activities to be reported are the conclusion, termination and modification of any securities financing transaction;
  • Reporting is on a T+1 basis for all activities;
  • Records must be maintained for a minimum of 5 years after the termination of the transaction;
  • Where Repositories detect that both sides of the trade are subject to SFTR reporting, they should ensure that the details reported by both parties match;
  • Reports made to TRs must be in the ISO20022 XML format – other formats (such as csv, Excel, FpML, FIXML etc.) must be rejected by TRs.

What is different?

  • Different asset classes: the transactions required under SFTR comprise repurchase agreement, securities lending or borrowing, commodities lending or borrowing, buy-back/sell-back, margin lending and total returns. On the other hand, EMIR covers derivatives in equities, fixed income instruments, interest rates, foreign exchange and commodities;
  • Scope and extraterritoriality of the regulation – under SFTR, any counterparty engaging in an SFT and reuse of collateral including branches, wherever they may be located, will need to report;  
  • Branch obligation to report – under SFTR, the EU branches of non-EU entities have the obligation to report to an approved EU trade repository. Moreover, EU branches of 3rd country entities are obligated to report if the SFT is concluded in the course of the operations of a branch in the EU of the counterparty.