One of ASIC’s goals is to align the Australian reporting regime with international standards. Harmonising the data collected according to the critical data elements introduced in the CDE Guidance aims to improve data quality for sharing between regulators globally.
The updated ASIC OTC derivative transaction reporting covers 128 fields. Of these, 107 fields are transaction information, 16 related to valuation data and 25 for collateral details.
So, what new information do firms need to send TRAction so we can complete your reporting once the new ASIC regime does live in October 2024?
Counterparty details
The counterparty details required for ASIC are still not as extensive as those required for similar global regulations (such as EMIR), however, there is one new field being introduced. This data element will enable ASIC to monitor the nature and geographic region of the parties involved in a transaction.
| ASIC Rewrite Field Name | What it means | What you need to do |
| Country of counterparty 2 | When the Counterparty 2 field is not populated with an LEI, country of residence or registered business address is required. | Use the name of the client’s country where there is no LEI. |
Unique Product Identifier (UPI)
The role of the UPI is to uniquely identify an OTC derivatives product. A unique UPI code signifies a collection of specific values on the reference data elements which resides in the UPI Reference Data Library on ANNA-DSB.
If a UPI code already exists for your OTC derivative, you will have to obtain the UPI code from the UPI Library.
If a UPI is not available on the UPI Library, you will have to provide Anna-DSB with a relevant set of reference data elements values which represent a unique combination of characteristics related to the OTC derivative product.
When ASIC Rewrite goes live, the UPI will have to be updated to outstanding OTC derivatives, even if previously they were identified with an ISIN.
| ASIC Rewrite Field Name | What it means | What you need to do |
| Unique Product Identifier (UPI) | This field is applicable only to OTC derivatives. | Obtain UPI from the UPI Library maintained by ANNA DSB. |
Unique Trade Identifier (UTI)
As per Part 2.2.9 of 2024 Rules, reporting counterparties have to pair each unique transaction between trading parties using the UTI. Firms are expected to refer to Table 2 on which firm should generate the UTI in different situations. However, firms with sizeable trades will likely have a ‘bilateral agreement’ on UTI generation with their counterparties
Platform identifier
Equivalent to the ‘‘Venue’ field in European regulations (like EMIR and MiFIR), this field is part of the critical data elements in the CPMI IOSCO CDE Guidance which identifies the trading facility on which the transaction was executed.
| ASIC Rewrite Field Name | What it means | What you need to do |
| Platform Identifier | MIC code – value of the facility XOFF – if not entered on a facility but able to be traded on a facility XXXX – if not able to be traded on a facility BILT – if firms cannot determine able to be traded on a facility | Begin recording this information to send to TRAction if you execute on several different facilities. |
Small-scale buy-side Entity Indicator
Under the 2024 Rules, firms will need to consider if the small-scale buy-side entity exemptions could apply. Reporting Entities with certain licensee criteria, as mentioned in Part 1.2.3, holding less than $AUD 12 billion in total gross notional outstanding non-centrally cleared derivatives in consecutive quarters are deemed small-scale buy-side entities. These entities are entitled to certain exemptions (Part 1.3.1(4)) such as lifecycle reporting (except equity derivatives) and collateral/margin details.
Interest Rates related fields
ASIC has introduced additional data elements in relation to the interest rate spread, on top of the existing interest rate fields.
| ASIC Rewrite Field Name | What it means | What you need to do |
| Spread notation – Leg 1 and Leg 2 | 1 – if Spread is reported as monetary amount 3 – if Spread is reported as decimal 4 – if Spread is reported in basis points | TRAction will do the calculation and no additional information is required from firms. |
| Spread – Leg 1 and Leg 2 | Value of the Spread that is added to the reference rate | TRAction will reach out to you to update the necessary required information. |
| Spread currency – Leg 1 and Leg 2 | The currency of the Spread | TRAction will reach out to you to update the necessary required information. |
Options related fields
As part of harmonising the data elements according to the CDE Guidance, there are a number of new option-specific fields being introduced.
| ASIC Rewrite Field Name | What it means | What you need to do |
| Delta | This a valuation field which must be reported on a daily basis * Not needed for small-scale buy-side entities | Calculate the ratio of the change in price of a derivative to the change in price of the underlying. |
| Option premium payment date | The date on which the option premium is paid. | TRAction will reach out to you to update the necessary required information. |
The changes in ASIC Rewrite aim to align the regime with agreed upon global standards and to improve data quality. Should you need further clarification on how ASIC Rewrite will affect your business operations or if you are overwhelmed by the additional requirements outlined, please get in touch with us.
