The Safe Harbour Benefits of Delegated Trade Reporting under ASIC Rules

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What Is Delegated Reporting for OTC Derivatives?

Until the commencement of the new ASIC trade reporting rules on 21 October 2024, a reporting entity receives a safe harbour benefit when it appoints one or more persons (each a delegate) to report OTC derivatives on its behalf. This delegate may be a counterparty, a central counterparty, a trading platform, a service provider, a broker or any other third party.

After 21 October 2024, firms can continue to delegate their reporting, however the safe harbour provisions will be mostly removed from the ASIC rules. This means that firms will need to implement greater monitoring and reconciliations of their ASIC trade reporting.

For those firms already delegating their reporting, we encourage you to use this transition period to build an understanding of how to conduct regular reconciliations and monitoring. TRAction have compiled resources for both clients and non-clients to assist with this process.

What are the Safe Harbour benefits?

You are taken to have complied with your reporting obligations in relation to each reportable transaction and reportable position for which your delegate has been appointed to report, subject to certain conditions.

What are the conditions?

You can only benefit from the safe harbour provision if:

  1. the terms of the delegate’s appointment and any related agreements or arrangements are documented in writing
  2. you make regular enquiries reasonably designed to determine whether your delegate is discharging its obligations under the terms of its appointment; and
  3. you remain responsible for taking all reasonable steps to ensure the completeness, accuracy and currency of the information reported by your delegate.

Refer to ASIC Reporting Rules 2.2.1 – 2.2.5 and 2.2.8 for more information.

Can I delegate reporting to multiple delegates?

Yes, you can and you can also rely on the safe harbour provision if all the above conditions are satisfied with each delegate. Where you delegate to multiple delegates, you will need to ensure that each OTC derivative transaction you enter into is covered by one of the delegation agreements. Where particular transactions are not covered by a delegation agreement, the reporting entity will remain responsible for reporting these transactions in accordance with the Reporting Rules.

If you have any questions, please feel free to contact us.

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