Counterparty Reference Data and Enrichment Service
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- Buddy Moore
- 8 years ago
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1 The global derivatives market is preparing for new regulatory reporting requirements scheduled for 12 th February One of the main challenges for a reporting party in providing counterparty delegation is the collection, storage and maintance of the propriety counterparty data of the client wanting to delegate reporting. The Counterparty Reference Data and Enrichment service is an industry supported solution that collates and disseminates the required EMIR counterparty data. This empowers the client to own and manage their own data fields and therefore provides the reporting party with a simple data collection method to support delegation. If your firm has decided to offer clients delegated reporting through CRDE, the following outlines the simple steps required by your client and yourself to enroll in the service. STEP 1. LEGAL ENTITY IDENTIFIER (LEI) ESMA and other European competent authorities have clarified their desire for all entities included in Trade Repositories to be identified by an LEI. LEI s for each legal entity can be obtained at or by contacting your DTCC account manager below. STEP 2. CRD REPORTING PARTY IDENTIFIER CRD requires the client to identify the reporting parties that will have access to their counterparty data. CRD is prepopulated with the ISDA Primary dealers If you are not one of these primary dealers but want to offer this service to clients please contact your account manager and they will arrange for your company to be added to the reporting party selection list. STEP 3. CRD - COUNTERPARTY REFERENCE DATA The first requirement for your client is to submit their responses for the 15 EMIR proprietary counterparty data values (see Appendix 1) to CRD as well as identify the reporting parties that can have access to this data. This ensures they only have to provide the data once and enables you as the reporting party to access only the data they want you to see. Additionally, this enables the GTR to utilise their counterparty data values to complete their EMIR trade records.
2 Proprietary Counterparty Data Reporting Party Client CRDE is designed to be an invitation only service; this is to ensure that only parties that have formally arranged delegation with their reporting parties can submit data to CRDE. This is achieved through the following steps: 1. Once you have agreed to provide the service to your client, please send them the following link This link can also be embedded in your delegation agreements with your clients. 2. Once the client has received the link they will be invited to submit their 15 counterparty data values and identify their reporting parties. A full set on CRDE client instructions is available on the CRD (CRR) utility website. Once this is completed, you and the GTR have the necessary information to complete your trade records and perform the delegated reporting on behalf of your client. STEP 4. GTR ON-BOARDING (OPTIONAL) As part of the arrangement with your client, you may want them to on-board to the GTR. This will enable them to view the records that you have reported on their behalf as well as report their own data separately if required. There are two options if they wish to on board: Single entity If they have only one entity to on-board then they can complete this through our online registration portal. Multiple entities If they have multiple entities to on-board then they will need to go through our in person onboarding process which can be arranged by ing. Either way, if the client contacts the DTCC on boarding team at gtr_onboarding@dtcc.com. They will work with them to ascertain which on boarding method best suits, and send them either the login details for the online registration portal or the on boarding forms for manual on boarding.
3 STEP 5. CRE - COUNTERPARTY REFERENCE ENRICHMENT w that the client data is stored in CRD, you have two options in how this data is used. Reference Data GTR Enrichment Reporting Party CRD GTR/CRE Reference Data only. CRD offers the ability for the reporting party to source the client data via CSV format. This can then be integrated within your own reporting tools or services. Auto GTR Enrichment. The key benefit of CRD is the automatic enrichment of counterparty data onto reportable trades that have been delegated and submitted to the GTR, by you the reporting party. This enables you to just submit the common data and LEI of the counterparty and DTCC will enrich the missing counterparty fields directly from CRD. Where possible this leverages the existing GTR message formats and procedures for OTC Core and ETD (OTC Lite will follow later). The simple steps are out lined below. Trades requiring enrichment need to be sent to a separate and specific queue, utilising the submission types: o FpML over MQ o CSV o FPML via SFTP The reporting party sends the trade record with delegation flagged as required. The record needs to contain the common data, the reporting party s full counterparty data and the LEI of the client. The Counterparty Reference Enrichment (CRE) service will intelligently source the client s counterparty data from CRD, automatically enrich the counterparty data for the reportable trade, and then send the complete record to the GTR to store both reportable sides of the trade. This is done utilising the client s LEI and the reporting party access rights granted by the client in CRD. The client (if on boarded to the GTR) can then access the GTR to see their record of the trade with the EMIR specific common and their own counterparty data fully completed.
4 STEP 6 CRE - COUNTERPARTY REFERENCE ENRICHMENT CLIENT CONTROL With the completion of step 5 the full record of the trade is held in the client s GTR account, with the counterparty data populated from data the client initially input into CRD. However, there may be circumstances, such as purpose of trade where the clients default value in CRD is not applicable to a specific trade. Utilising CRE the client has the ability to submit an update message which will override any of the 15 proprietary counterparty data values. This allows the client to own and change their data without the involvement of the reporting party. More details about this part of the service will be provided shortly. To find out more about this solution please contact your GTR Account manager. APPENDIX 1 CRR REQUIRED COUNTERPARTY DATA FIELDS uestion Name Description Values Q1 LEI and Entity name Pre-populated by DTCC or dealer Interim entity identifier or Legal Entity Identifier (LEI) Q2 EEA counterparty Indicates whether this counterparty is domiciled inside the European Economic Area (EEA). Q3 Financial or nonfinancial nature of the counterparty Indicates whether the reporting counterparty is a financial or non-financial counterparty in accordance with points 8 and 9 of Article 2 of Regulation (EU) 648/2012. F=Financial Counterparty N=n-Financial Q4 Corporate sector of the counterparty Indicates the nature of the reporting counterparty s company activities (bank, insurance company, etc.) A = Assurance undertaking authorised in accordance with Directive 2002/83/EC C = Credit institution authorised in accordance with Directive 2006/48/EC F = Investment firm in accordance with Directive 2004/39/EC I = Insurance undertaking authorised in accordance with Directive 73/239/EEC L = Alternative investment fund managed by AIFMs authorised or registered in accordance with Directive 2011/61/EU O = Institution for occupational retirement provision within the meaning of Article 6(a) of Directive 2003/41/EC R = Reinsurance undertaking authorised in accordance with Directive 2005/68/EC U = UCITS and its management company, authorised in accordance with Directive 2009/65/EC]
5 uestion Name Description Values Q5 Directly linked to commercial activity or treasury financing: Indicates whether the contract is objectively measurable as directly linked to the reporting counterparty s commercial or treasury financing activity, as referred to in Article 10(3) of Regulation (EU) 648/2012. Blank Q6 Clearing threshold Provides information on whether the counterparty is above the clearing threshold as referred to in Article 10(2) of Regulation (EU) 648/2012. Q7 Trading capacity Identifies whether the reporting counterparty has concluded the contract as principal on own account (on own behalf or behalf of a client) or as agent for the account of and on behalf of a client. Q8 Broker ID Type In case a broker acts as intermediary for the reporting counterparty without becoming a counterparty, the reporting counterparty shall identify this broker by a unique code. In case of an individual, a client code shall be used Principal Agent Blank (no defaulted value) Interim entity identifier or Legal Entity Identifier (LEI) SWIFT BIC (11 alphanumerical digits) Client code (max: 50 alphanumerical digits) identifier submitted Q9 Broker ID Value Broker identifier value Text Field Q10 Clearing member ID Type In case the reporting counterparty is not a clearing member, its clearing member shall be identified in this field by a unique code. In case of an individual, a client code, as assigned by the CCP, shall be used. Interim entity identifier or Legal Entity Identifier (LEI):SWIFT BIC (11 alphanumerical digits) Client code (max: 50 alphanumerical digits) identifier submitted Q11 Clearing member ID value Clearing member identifier value Text Field Q12 Beneficiary ID Type The party subject to the rights and obligations arising from the contract. Where the transaction is executed via a structure, such as a trust or fund, representing a number of beneficiaries, the beneficiary should be identified as that structure. If the beneficiary of the contract is not a counterparty to this contract, the reporting counterparty has to identify this beneficiary by a unique code or, in case of individuals, by a client code as assigned by the legal entity used by the individual Interim entity identifier or Legal Entity Identifier (LEI): SWIFT BIC (11 alphanumerical digits) Client code (max: 50 alphanumerical digits) identifier submitted Q13 Beneficiary ID value Beneficiary identifier value Text Field
6 uestion Name Description Values Q14 Investment Manager Have you completed this information as an Investment Manager or Asset Manager for a managed money account which could have multiple managers? Q15 Investment Manager ID If the answer to Q14 is yes, then identify the Investment Manager. Can only be identified by Interim entity identifier or Legal Entity Identifier (LEI) Text Field
Counterparty Reference Data and Enrichment Service
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