The consultation paper (CP361a) released by ASIC earlier this month can be seen as a very positive outcome of effective dialogue between regulators and market participants.
The new data elements that have been put forward are reflective of the feedback provided by market participants and include a clear summary of the need for those new data elements.
Here’s a summary of the content within CP361a that would no doubt require some attention:
Seven new data elements:
- 1a Secondary transaction identifier
- 7a Counterparty 2 name
- 59a Lower or only barrier price
- 59b Upper barrier price
- 58a Lower or only barrier price notation
- 58b Upper barrier price notation
- 105 New Derivative Trade Repository.
On 24 existing fields:
- ASIC has provided further clarification on how to report on 17 fields. Some notable clarifications to point out:
- Alignment with CDE to restrict negative notional amounts to commodity derivatives only
- Call and Put Amounts are not required for digital options
- Data elements related to other payments is expected for partial and full terminations
- Changes to seven fields that are fairly cosmetic in nature (for example, Field 13 ‘Execution agent of the Counterparty 1’ to ‘Execution agent of Counterparty 1’) or updating references from ‘Identifier’ to ‘Indicator’ for Field 86 ‘Identifier of the floating rate—Leg 2’
Clarifications on any regulatory reporting is always welcome given the complexities. But given the timing, any late changes would undoubtedly put more pressure on existing project workstreams. Firms will have to impact assess the latest changes and work out how best to minimise any negative impacts late changes can bring to any project.
The consultation closes on 15 December 2023 and a quick turnaround of the publishing of the ‘final’ changes is likely to be on a firm’s Christmas wish list!