Presentation on theme: "EMIR Collateral and Valuation Reporting"— Presentation transcript:
1EMIR Collateral and Valuation Reporting fdaOTCLite WebinarEMIR Collateral and Valuation ReportingV1.2 updated 31May14
2Regulatory OverviewReporting start date for Collateral and Valuation is August 11th 2014Derivative contracts still outstanding on 11th August 2014must include information pertaining to collateral and valuation as from that date;need not include information pertaining to collateral and valuation prior to that date.Contracts that are terminated before 11th August 2014 need not include information pertaining to collateral or valuations.Collateral and valuations must be reported on a daily basis by financial counterparties and non-financial counterparties who exceed their clearing threshold as referred to in Article 10(3).Participants can delegate reporting of collateral and valuation to their counterparties or a third party provider.Collateral and valuation is reported as Counterparty data therefore, counterparties do not need to agree the data reported.
4Trade Valuation Reporting Trade valuations must be submitted to GTR daily. Submissions can be made to GTR intra-day or at the end of day.No calculation will be performed on valuations and the latest report, based on the as of date time, will be considered the current valuation for that day.Valuation data can be submitted using any of the following messages*:Valuation messagePosition messageWith reference to transactions cleared by a CCP, valuations should be reported on a daily basis at position level, as maintained and valued by the CCP.For Non-Financial counterparties who are below the clearing threshold, there is no obligation to report valuation data.Any trade valuations submitted by NFC (minus) parties will be withheld and will not be included on regulatory reports.As a result of the above, all valuations reported by, or on behalf of, NFC (minus) parties will not be populated on regulatory reports.*For submissions to the core applications users can also submit valuations as part of Snapshot messages
5Trade Valuation Reporting For OTC Core and OTC Lite, users can submit valuations through a different service than the associated trade.A valuation can be reported through OTC Lite even if the associated trade has been reported through an OTC core asset class.Valuations cannot be submitted through OTC Core for trades reported through OTC Lite.Valuations reported through a different service to the associated trade will only be reported on the ESMA OTC Position report and the ESMA OTC Activity report.Valuation messages submitted through OTC Lite will be included in reports produced from the OTC core asset classes (i.e. the Enhanced Position Reports).Delegated reporting of valuation messages will follow the same rules as delegated reporting of trades but can be applied independently of the reporting of trades. A firm can delegate reporting of their trades but independently report the valuation of those trades or vice versa.The valuation reported will be that with the latest valuation date time reported for that day, regardless of data submitter. It will no longer be the case that any self-submission takes precedence over a delegated submission.There are no jurisdiction or obligation fields on the valuation messageReporting of the valuations will be determined by the reporting obligations specified on the associated trades.The message routing to the correct data center is indicated by providing information in the “sendTo “field on the inbound messageFor OTCLite submissions you can include both position AND valuation submissions on the same csv spreadsheet upload as each line will indicate what type of message is being used. The csv will still require the use of the footer in order to process.
9Collateral Valuation Message A new collateral valuation message has been created to provide for the reporting of the value of collateral. It is a cross-asset message published on its own templateAll collateral valuations, including those applicable to individual transactions, must be reported using this message. Collateral valuations will not be accepted on trade/position messages.Collateral valuation messages must be submitted daily by the poster of the collateral. If no submissions are received for a particular collateral portfolio code on a given reporting date, none will be reported to the regulators.The party posting collateral has the obligation to report, therefore the Collateral Value Message will always be provided by, or submitted on behalf of, the party positing the collateral.Portfolio code, Collateral Value and Collateral Currency are all from the posters perspective.The Collateral message report the value of the collateral that has currently been posted for that date – not the movement of collateral day on day
10Collateral Valuation Message Collateral valuations must be reported on behalf of the same entity that is named as the party to the trade (this can be party 1 or party 2 on the trade message).Submissions will be made against a new o-code to facilitate a cross asset solutionFor incorrect submissions, a new (corrected) submission should be made (rather than exit/termination) and if multiple collateral valuation messages are submitted on a given reporting date, the latest valuation date/time is considered the current value.Where a collateral value message has been reported when collateral does not need to be reported (e.g. the receiver of the collateral has reported) a cancel message will be available to remove the collateral valuation.Collateral valuations will only be reported to regulators once successfully linked to a reported trade.There are no jurisdiction or obligation fields on the collateral valuation messageRegulatory reporting of collateral valuations will be determined by the reporting obligations specified on the associated trades.The message routing to the correct data center is indicated by providing information in the “sendTo “field on the inbound message
12Collateral Valuation Message Note: additional clarification from ESMA indicates that collateral is expected in one currency only.DTCC templates in the process of being updated accordingly
13Collateral Valuation Example ScenarioCollateral HeldParty 1 Collateral valuation actionParty 2 Collateral valuation actionDay 1Party 1 posts 1000 EUR as collateral to party 2Party 2 holds 1000 EUR in collateralParty 1 submits collateral valuation message for EUR1000 using their collateral portfolio codeNo action neededDay 2Party 1 received 200 EUR from party 2 in collateral margin movementParty 2 now holds 800 EUR in collateralParty 1 submits collateral valuation message for EUR800Day 3Party 1 received 100 EUR form party 2 in collateral margin movementParty 2 now holds 700 EUR in collateralParty 1 submits collateral valuation message for EUR700Day 4No change in collateral margin movementParty 2 still holds 700 EUR in collateralParty 1 submits collateral valuation message for EUR700*Day 5Party 1 received 1000 EUR form party 2 in collateral margin movementParty 1 now holds 300 EUR in collateralParty 2 submits collateral valuation message for EUR300 using their collateral portfolio code (which can be different to the portfolio code used by Party 1)Day 6Party 1 posted 100 EUR from party 2Party 1 now holds 200 EUR in collateralParty2 submits collateral valuation message for EUR200* Note that on day 4 even though there is no change in the collateral being held if there is no submission of a collateral valuation message that day then collateral will not be reported to ESMA for that day. Party 1 still needs to submit the collateral valuation even though there has been no movement in collateral that day
15Collateral LinkingThe GTR provides two methods for linking collateral portfolios to trades.Using trade messagesCollateral portfolio codes can be specified on trade submissionsUsing a Collateral Link messageThe collateral portfolio code and the collateralization type can be submitted on the existing trade messages (position message for OTCLite).A new Collateral Link Message can be submitted to link each trade to be associated with a collateral portfolio.The trade should be identified using a UTI, USI or Trade Party Transaction Id (or any combination thereof).Reporting of collateral will be based upon the open trade population and not the collateral portfolios.If a collateral portfolio code exists on an open trade the information held on the trade will be used to extract collateral valuation data. The collateral value will be identified using:Trade Party 1 Value / Trade Party 2 ValueExecution Agent Party 1 / Execution Agent Party 2Collateral Portfolio Code Party 1 / Collateral Portfolio Code Party 2All three fields must match exactly between the trade and the collateral value.
16Collateral LinkingIf the collateral portfolio code does not exist on the trade message GTR will look for a collateral link message. The collateral link message will be identified usingA trade identifierIf UTI matches the UTI will be usedIf no match is found on UTI the USI will be usedIf no match is found using UTI or USI the Trade Party 1 Transaction Id will be usedTrade Party 1 Value / Trade Party 2 ValueExecution Agent Party 1 / Execution Agent Party 2Once a collateral link message is identified GTR will look for the collateral value using:Collateral Portfolio Code Party 1 / Collateral Portfolio Code Party 2 extracted from the link messageAll three fields must match exactly between the trade and the collateral value.Collateral linking is NOT required to be submitted every day. Only additions to the portfolio need to have a collateral linking message submitted (if the portfolio is not identified on the position message)You do NOT need to make a new collateral linking submission to remove a trade from a portfolio is it has matured or terminated, but you should submit a cancel to remove a trade from a portfolio if it had been added incorrectly
20Participant Reports MtM Valuations The reports that will be updated to include valuations are:Enhanced Position Reports (for each OTC core asset class where the valuation has been submitted through that asset class and not through OTC Lite)ESMA OTC Position Report (Includes Core and Lite)ESMA ETD Position ReportESMA OTC Activity Report (Includes Core and Lite)ESMA ETD Activity ReportSubmission report (excludes Lite)Warning Report (Includes ETD, Core and Lite)Valuations submitted through OTC Lite will not appear on OTC core reports, they will only appear on the consolidated ESMA OTC Position and Activity Reports.
21Participant Reports Collateral Valuations Collateral valuations will not be populated on the GTR position reports. This exclusion will apply toEnhanced Position ReportsESMA OTC Position ReportESMA ETD Position ReportESMA OTC Activity ReportESMA ETD Activity ReportThe following fields will be added to the above reports but will not be populated:CollateralisationValue of the collateralCurrency of the collateral valueThe following fields will be added to the above reports and will be populated if submitted via trade messages. They will not be populated if submitted on Collateral Link messages.Collateral Portfolio IndicatorCollateral portfolio code
22Participant Reports Collateral Submission Report A new collateral report will be created to indicate collateral posted by the report recipientThis will provide participants with a view of the collateral that is reported as being posted by them.The collateral reports will be asset class and service agnostic, meaning all collateral from the OTC Core, Lite and ETD service will appear on the same collateral report.The report will only show data related to the trade party where that party has reported the collateral. The report will include the following fields:Trade Party PrefixTrade Party ValueExecution Agent prefixExecution Agent ValueData Submitter prefixData Submitter valueCollateral portfolio codeValue of the collateralCurrency of the collateral valueSend ToUsers will only be able to access collateral reports where they are posting collateral.This report will be available for download under a new o-code.
23Participant Reports Counterparty Data Masking When reporting an allege message on position and activity reports the following fields will be masked:MTM Value Party 2MTM Currency Party 2Valuation Datetime Party 2Valuation Type Party 2Collateral portfolio codeCollateral Portfolio IndicatorCollateralizedValue of the collateralCurrency of the collateral value
24Warning ReportsCollateral warnings will not be produced because given the method proposed for reporting collateral to participants and regulators it will not be possible to provide warnings for those portfolios not linked to trades.Valuation warning reports will be introduced. Note that valuation warnings are produced in end of day reports, there are no warning messages (WACKs) associated with valuation submissions.Valuation warnings (NFC(minus) excluded from this population) :Where there is an obligation to ESMA and no valuation has been received.Where there is an obligation to ESMA and no valuation has been received for the current day.One exceptional scenario exists whereby the data submitter will not receive this warning report.If a trade is reported through an OTC core asset class and valuation reporting is delegated to a third party who uses OTC Lite, it will be possible to provide warnings to the trade parties but not to the third party data submitter
25Summary Valuation Collateral Valuation Collateral Linking Messages Position MessageValuation MessageCollateral Valuation MessageCollateral Linking MessageActionNew only(correction by subsequent New)New and CancelWho SubmitsAll parties to the trade that have a reporting obligation to ESMA (unless non-financial under the clearing threshold)The poster of collateralWhen they submitEvery day the position is live, on a T+1 basisEvery day that collateral is posted regardless of whether the collateral held changed that day or notOnly when the transactions in a given portfolio changesImplication of not submittingLast known (stale) valuation is reported to ESMANo collateral is reported to ESMACollateral valuation only reported to ESMA if linked to a live position
26OTC Lite Client Support Dedicated OTCLite webpage(http://www.dtcc.com/en/data-and-repository-services/global-trade-repository/otc-lite.aspx)Includes recorded presentations, user guide, connectivity guide, up to date template and a schedule of online demonstrationsDedicated OTC Lite Support teamSupport available in multiple European languagessupport: (UAT queries); (production queries)Hotline support:Europe/UK/Asia: +44 (0) (Options 1,3)Regular live webinars available in multiple European languages (schedule published on the OTCLite website)
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