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MAS Reporting

The Monetary Authority of Singapore

The Monetary Authority of Singapore (MAS) requires parties to a Specified Derivative Contract (SDC) to report to a licensed trade repository or licensed foreign trade repository under the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013.

Major rule changes are being implemented in October 2024, known as MAS Rewrite.

What is the reporting obligation?

MAS requires only certain over-the-counter (OTC) derivative contracts to be reported. Exchange-traded derivatives contracts including futures contracts and block futures contracts are not in the scope of the regime and therefore, they don’t need to be reported.

TRAction has summarised which OTC SDCs are to be included and excluded in your MAS trade reports in the table below:

Please refer to section 2 of the Regulations for detailed definitions of these five types of reportable derivatives.

Who is required to report?

The following entities are required to report subject to exemptions:

  • any holder of a capital markets services licence (CMSL) subject to exemption;
  • any Significant Derivatives Holder (SDH) as set out in section 6 of the Regulations (see below for more detail);
  • any bank in Singapore licensed under the Banking Act (Chapter 19);
  • any subsidiary of a bank incorporated in Singapore subject to exemption;
  • any merchant bank approved as a financial institution under the Monetary Authority of Singapore Act;
  • any finance company licensed under the Finance Companies Act; and
  • any insurer licensed under the Insurance Act subject to exemption.

 

This is covered at Section 124 of the Act and Section 6 of the Regulations,

Who is not required to report?

The following are exempt from reporting under MAS Rewrite:

  • an approved trustee (under s.289 of the Securities Futures Act 2001);
  • a licensed trust company that entered into the relevant OTC as a trustee;
  • the following, if they either have carried on its business or operations for less than 4 consecutive quarters; or if the conditions in regulation 10C(4) (for (i) and (ii) below) or regulation 10A(4) (for (iii) below) of the Regulations are met (i.e. refers to the bookings of trades with aggregate gross notional amounts being less than $5b):
    (i) a subsidiary of a bank incorporated in Singapore,
    (ii) a licensed insurer; and
    (iii) a Capital Markets Service Licensee.
  • persons listed in the Fourth Schedule to the Regulations e.g. Singaporean Government central banks, multilateral development agencies and international organisations.


Other exclusions from reporting

Under MAS Rewrite, derivative contracts entered into between a CMSL and a person who is not an accredited investor or institutional investor are exempt from reporting. This effectively means derivative contracts between CMSLs and expert investors need to be reported.

[References:
• Regulations 10 and 10A of the SF(RDC)R
• Fourth Schedule to the SF(RDC)R)]

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Who are Significant Derivatives Holders (SDH)?

  • The person does not fall into any category above (see Who is required to report?);
  • The person is a resident in Singapore; and
  • The person’s aggregate gross notional amount of SDCs which are traded in Singapore for the year exceeds SGD 8 billion.

What to report and to whom?

Depending on the class of SDCs, the reporting details required are different. The following are the reporting information fields required for all classes of SDCs:

  • contract information such as Unique Transaction Identifier (UTI);
  • counterparty information such as Legal Entity Identifier (LEI);
  • clearing information;
  • contract confirmation;
  • trade execution;
  • transactional data;
  • timestamp information; and
  • option data, if applicable.

 

All MAS OTC derivative trades are to be reported to a designated TR regulated under MAS. As it stands, DTCC is the only regulated TR for Singapore MAS trade reporting. Reporting entities are required to report the trade information described below within two (2) business days (T+2).

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Further Information

With similar to changes in other jurisdictions, MAS Rewrite aims to align their standards with the wider APAC region and to increase transparency. Continuing with global harmonisation, MAS has decided to adopt the ISO 20022 XML message format, and will follow in the footsteps of other jurisdictions by tackling this with a single-phase rollout.

MAS have released their updated guidelines for regulatory reporting and outlined the final rules that will come into effect on 21 October 2024.

Yes. There are a number of changes to field such as UTI, UPI, Collateral, FX Swap Link ID and Package Identifier, to name a few.

The MAS OTC Derivative Reporting Final Phase is in force. As a result, TRAction expanded its reporting services to support clients reporting under the MAS regime with our end-to-end delegated reporting solution. Read more.

As the scope of MAS OTC Derivatives reporting increases, so too, can the difficulty of keeping on top of your reporting obligations. We recommend you consider maximising the effectiveness of your team by using specialist regtech companies such as TRAction. Read more.

With the final phase of the MAS OTC Derivative Reporting Regulations now in force, our team has found that some firms are unaware they are captured under the regime. This is why we’ve developed the MAS Assessment Tool. Read more.