MAS Rewrite goes live on 21 October 2024. MAS Rewrite is being implemented as part of regulatory efforts to harmonise with the global changes to the derivative reporting framework.
For further background see our article in which we discuss the ‘Key takeaways from recent MAS updates to OTC derivative reporting guidelines and FAQs’ here and the ‘MAS Rewrite updated FAQs’ here.
Additional Information Required
Important things to note before commencing reporting for MAS:
- Firstly, reporting entities should take note that the reporting deadline under MAS Rewrite is T+2 (i.e. 2 business days post trade execution).
- Secondly, there is now an increase in the number of total reportable fields, which is now 134.
Below, we set out the additional information that needs to be collected (or considered) for reporting purposes:
Counterparty details:
| MAS Rewrite Field | What it means | What next? |
|---|---|---|
| LEI – Clarification for branches | A legal entity identifier (LEI) is a 20-digit alpha-numeric code based on the standard developed by the International Organization for Standardization (ISO) – see our article here further information on LEIs. | If a reporting entity is a branch, it should report the LEI associated to the head office. The same should apply also in the reverse where its counterparty is a branch, to use its head office’s LEI. TRAction assists its clients in obtaining and renewing LEIs. |
Unique Transaction Identifier (UTI):
| MAS Rewrite Field | What it means | What next? |
|---|---|---|
| Unique Transaction Identifier (UTI) (including interim UTIs) | A code which represents a specified derivatives contract or a reportable OTC derivatives contract in a foreign jurisdiction. An interim-UTIs are UTIs that can be obtained where a final UTI is not generated/available in time to meet reporting deadlines. When getting the UTI, reporting entities will need to identify who ‘specified persons’ and ‘UTI generating entities’ are. | Before generating a UTI, the ‘UTI generating entity’ must be determined (i.e. the party who is to generate the UTI) – this can be done by using Table 1 in the MAS Guidelines. If there is difficulty in determining the UTI generating entity with the use of Table 1, parties can enter into a bilateral agreement to have these issues addressed there. |
Unique Product Identifier (UPI):
| MAS Rewrite Field | What it means | What next? |
|---|---|---|
| Unique Product Identifier (UPI) * Applicable only to OTC derivatives | A code which represents the nature of the reported product or instrument as it relates to reference data elements | Go to ANNA-DSB website and obtain a UPI from the UPI Library. TRAction assists its clients in doing this search or registering UPIs as required. |
Additional Fields for population and consideration
We have highlighted below the data fields to populate or issues that need consideration for reporting under MAS Rewrite. For more detail on the critical data elements and discussion of scenarios for the relevant data fields, see Table 2 in the MAS Guidelines (page 15).
| MAS Rewrite Field | What it means and how to report? |
|---|---|
| Package Identifier | Any alphanumeric value (100 characters or less) which is to be determined by the reporting entity when connecting 2 or more separately reported trades. |
| Event Type | This is where an explanation or cause is shown for the action taken on the contract (if applicable) – some of which include Novation, Compression, Corporate Event, Credit Event, Transfer, Clearing & Allocation and Early termination. |
| Action Type | This is where the type of action taken on the contract is shown. Field values that can be elected are: • “NEWT” = New • “EROR” = Error • “MODI” = Modify • “CORR”= Correct • “TERM“ = Terminate • “MARU”= Collateral/Margin update • “VALU” = Valuation • “REVI” = Revive |
| Asset Class | This represents the asset class of the derivatives contract. Field values that can be selected are: • “COMM” = Commodity • “CRDT” = Credit • “CURR”= Foreign exchange • “EQUI”= Equity • “INTR” = Interest rate |
| Contract Type | This represents the contract type of the derivatives contract. Field values that can be selected are: • “CFDS” = Contract for difference • “FRAS” = Forward rate agreement • “FORW” = Forward • “OPTN” = Option • “SWAP” = Swap • “SWPT” = Swaption • “OTHR” = if any of the above are inapplicable. |
| Direction, Direction of legs (leg 1 and leg 2) | This is information that relates to the direction of the trade from the reporting entities’ perspective and needs to be reported e.g. specifying if Counterparty 1 or Counterparty 2 is a buyer or seller in the contract. Field values are: • “BYER” = Buyer • “SLLR” = Seller There is also a direction data field where you need to specify if Counterparty 1 or Counterparty 2 of the relevant leg of the trade is a payer or receiver. Field values are: • “MAKE” = Payer • “TAKE” = Receiver |
| Notional related fields | These include fields such as: • Notional Amount – refers to the notional amount of the contract or leg. • Notional Currency – refers to the currency the notional amount of the contract or leg is in. (There are various other Notional related fields in rows 76 to 93.) |
| Other payment types | This includes field values such as: • “UFRO” = Upfront Payment • “UWIN” = Unwind or Full termination • “PEXH” = Principal Exchange |
| Collateral – No Collateral is being posted | If no collateral is to be posted,, this also needs to be populated in the new data field: “Collateralisation category” as ‘UNCL’. Other collateral related data fields would be not applicable. |
| Category type of the collateral agreement | The category type of the collateral agreement, if it is not a Credit Support Annex (CSA)), also falls under the “Collateralisation category” section (discussed above). Reporting entities should therefore determine the collateral agreement type and whether there is a requirement under the collateral agreement to post collateral. |
| FX swaps | These are required to be reported as 2 separate transactions – both to be connected through a ‘FX Swap Link ID’ or in the case of other types of packaged trades such as swaptions, be connected through a ‘package identifier’. Note, when reporting a package, the spread also needs to be reported. |
| Report Format to be used | Submissions reported to trade repositories (TR) need to be in the ISO 20022 XML format, replacing the current CSV or fPML formats. |
Other relevant information for MAS Rewrite
Exemptions relating to collateral
Collateral and margin information is now mandated with specific exemptions available e.g. to agents or brokers where they would not be expected to have access to collateral information or for fund managers that execute derivative contracts on behalf of a portfolio it does not manage. To ascertain whether any exemptions apply, consideration of the role of the fund managers are important.
Can collateral information be reported at portfolio levels?
Yes, but only if the transaction is a part of a set of contracts. This means that information as to whether the contract is a part of a group of contracts is important to determine at the outset.
Contracts for Difference (CFDs) specifics
For CFDs, you can do position level reporting and also submit a transactional report.
Is Re-reporting necessary?
Re-reporting is only required for all outstanding derivatives reported prior to 21 October 2024 with a maturity of at least 6 months as at 21 October2024.
How can TRAction assist?
If you need assistance in understanding what additional pieces of information you need to report in a compliant manner under MAS Rewrite, get in touch with us.
