Time is running out for MAS regulated firms
Under the new MAS Rules for trade reporting, which began on 21 October 2024, there is a 6 month transition period provided to reporting entities. Outstanding contracts that were previously reported before 21 October 2024 and maturing on or after 21 April 2025, need to be re-reported or in other words, ‘uplifted’. This means they need to be updated to include the new requirements. These changes include LEIs, UTIs, UPIs and other additional data fields.
Re-reporting or uplifting of impacted trades need to be done by 21 April 2025. We provide more detail and examples on how to deal with impacted trades below.
What the action type would be used for re-reporting?
- MODI-UPDT – ‘Update’ – is where the action type is ‘MODI’ and the event type is ‘UPDT’ which is essentially for the updating/re-reporting of a legacy trade.
- MODI – ‘Modify’ – is for a reportable data field that was not previously reported before at all but needs updating.
Note for collateral, it is slightly different.
Timing of the re-reporting?
The MAS Guidelines has made it clear that all ‘re-reportable contracts’ i.e. contracts that mature on or after 21 April 2025, are to be reported by 21 April 2025 – the date of the end of the 6 month transition period. If a re-reportable contract is terminated, it should be reported within 2 business days of its termination. Any updates or variations of a re-reportable contract must be reported within 2 business days. See below how re-reportable contracts are treated, if they terminate before or on 21 April 2025.
If the contract terminates:
(a) before the 2nd last day of the 6 month period (i.e. before 20 April) – the contract is to be reported by 21 April 2025; or
(b) on the 2nd last day or last day of the 6 month period (i.e. on 20 or 21 April) – the contract is to be reported within 2 business days after.
Example of when to re-report
The table below shows how to re-report according to the maturity or termination of the trade.
For example, you have entered into a reportable trade such as an FX forward on 19 October 2024 with a 24 month maturity date – i.e. it expires on 19 October 2026 – refer to the last row ‘Maturing on or after 21 April.’
If, however, under the same transaction example, there was a termination that occurred on:
- 20 April 2025 – look at the middle row ‘Termination on either 20 or 21 April 2025’.
- 19 April 2025 – look at the first row ‘Termination before 20 April 2025’.
| Maturity Date or Termination Date | Detail | Last day of submission of MODI |
|---|---|---|
| Termination before 20 April 2025 | Derivative that terminates before 20 April 2025 (Sunday) – to be re-reported as MODI. | 21 April 2025 (Monday) |
| Termination on either 20 or 21 April 2025 | Derivative that terminates on either 20 April 2025 (Sunday) or 21 April 2025 (Monday) – to be re-reported as MODI. | Re-reporting to occur within 2 Business Days after termination. For example, the trade terminates on: • 20 April 2025 – then the last submission is 22 April 2025 (Tuesday) • 21 April 2025 – then the last submission is 23 April 2025 (Wednesday) |
| Maturing on or after 21 April 2025 | Derivative that matures on or after 21 April 2025 (e.g. including the example referred to above, where trade matures on 19 October 2026). | 21 April 2025 (Monday) |
Other things for consideration
- Any termination of a re-reportable trade should be reported within 2 business days of being terminated. Updates or variations to re-reportable contracts must also be reported within the same timeframe.
- Trades do not need to be updated in relation to collateral and valuation as reports of daily collateral and valuation updates during the transition period would naturally occur. However, re-reporting the details of a trade is required if it is about changes to any of its contract terms.
- For terminated or matured trades during the transition period, reports do not need to be submitted with ‘Update’ as the event type if no reportable changes occurred to the trade i.e. no updating or re-reporting is required for these.
- All outstanding derivatives are to be updated (trade and position level reporting).
- Re-reporting an ‘interim’ UTI as a permanent UTI.
What next?
If you are:
- An ongoing client of TRAction – we will perform the updates required on your behalf. If we need additional data from you such as any available UPIs, we will reach out to you shortly.
- Former one-off client of TRAction – please contact us and instruct us to update the affected transactions that we previously reported on your behalf so you can be compliant with the updated regulations.
- Non-TRAction client and doing the trade reporting yourself or through another entity, follow the below steps:
- Check that your current trades entered into on or after 21 October 2024, are compliant with the new MAS Rules. If there are any incidents, these need to be notified and reported to MAS in accordance with MAS’ incident reporting requirements.
- Consider and identify the re-reportable contracts that require updating along with the details that need to be changed.
- Submit reports by the deadlines as mentioned in the table above.
- Check that your current trades entered into on or after 21 October 2024, are compliant with the new MAS Rules. If there are any incidents, these need to be notified and reported to MAS in accordance with MAS’ incident reporting requirements.
How can TRAction assist?
If your affected trades need updating, get in touch with us. After instructions are received, we will assist in updating your re-reportable contracts and re-submitting the changes to your trade repository.
For new clients, TRAction will update all reportable transactions so they are compliant with MAS for no extra fee given this is included in our service arrangement.
For existing TRAction clients, and also reporting entities with one-off transactions, we can update your impacted transactions.
For more information on any updates to the global trade reporting regulations, please see our website here and do not hesitate to ask us any questions.
