Who has reporting obligations?
Both Financial Counterparty & Non-Financial Counterparty, which cover the following:
1. EU based entities including their non-EU based branches
SFTR will apply to investment firms who are established in the EU including all their branches, irrespective of where they are located.
2. Non-EU entities where the SFT is concluded by an EU based branch
SFTR will also apply to investment firms who are established in a third country but the SFT is concluded in the course of the operations of a branch in the European Union of that counterparty.
If the transaction was entered between a financial counterparty and a non-financial counterparty, the financial counterparty is required to report for both sides subject to the threshold requirement.
Who do you report to?
Authorised Trade Repositories (TRs) under SFTR
When do reports have to be made?
Reports are required to be submitted to an authorised TR by no later than one working day after the SFT has been made (T+1).
What information needs to be reported?
The SFTR will require the following information to be included:
- Counterparty data, including Legal Entity Identifiers (“LEIs”);
- Loan and collateral data, including Unique Transaction Identifiers (“UTIs”);
- Margin data; and
- Reuse information.
SFTR will also apply to outstanding trades
For the transactions that are entered on or before the reporting start date, they must be reported if they either:
(a) have a remaining maturity exceeding 180 days after the reporting start date; or
(b) have an open maturity and actually remain outstanding for 180 days after the reporting start date. In this case, the transactions must be reported within 190 days of the reporting start date.
How can TRAction assist you with the SFTR reporting?
TRAction provides clients with delegated reporting solutions in accordance with the reporting requirements outlined above. If you are wondering how much we charge, see our pricing schedules here.
If you would like to get further information, feel free to contact us.
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