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ASIC Announces Mandatory Lifecycle Reporting for CFDs, Margin FX and Equity Derivatives

From 1 July 2019, ASIC will require OTC derivative transactions on the following products to be reported using the ‘lifecycle’ method:

– CFDs;
– Margin FX;
– Equity derivatives.


What is the difference between lifecycle reporting and snapshot reporting?

Lifecycle reporting requires you to report the entry into, exit of, as well as any modification of an OTC derivative which occurred during the preceding business day. This is often referred to as ‘intraday reporting’.

Snapshot reporting, on the other hand, only requires you to report the positions which are open at the end of the business day. This is often referred to as ‘end-of-day reporting’.

Where are these changes coming from?

You can access the ASIC instrument here.

Under the current derivative transaction rules, reporting entities have an option to adopt either snapshot or lifecycle reporting. Nevertheless, rule 2.2.8(3) of ASIC Derivative Transaction Rules (Reporting) 2013 allows ASIC to determine certain derivatives to be “Excluded Derivatives” for using snapshot reporting, if such determination has one of the following effects:

– enhance the transparency of information available to relevant authorities and the public;
– promote financial stability; or
– support the detection and prevention of market abuse.

ASIC considers these changes will be useful for monitoring market misconduct and the prevention of market abuse in these products.

If you would like to know more about how TRAction can assist you with the transition to lifecycle reporting, please contact us.

Sophie Gerber

Sophie Gerber

Sophie has worked with some of Australia’s largest financial services organisations in compliance, legal and operational roles. She has also worked with small businesses to provide tailored solutions with a strong understanding of business practicalities as well as obligations to regulators. This strong understanding allows Sophie to effectively engage with not only large financial organisations but also with small businesses. Sophie has an in depth knowledge of compliance and legal obligations for financial services businesses having vast experience in the financial services sector. Sophie continually works with a range of companies in the financial services industry, including OTC derivatives brokers.