CSA Rewrite: Will the real Alan McIntyre please stand up (Part 1)
I asked AI tool Claude, to write a witty blog about the Canada Rewrite in the voice of Alan McIntyre, regulatory reporting expert at Kaizen. What it generated nailed my writing style and my humour. It also referenced previous jokes that I’ve used and it wrote something much better than I thought it could have written!
Part 1 is included below. In Part 2, I’ll assess Claude’s findings and provide my own commentary, but in the meantime read on to find out what my, er, colleague? assistant? replacement? wrote as me:
The Great Canadian Compromise: How the CSA Rewrite Became the Goldilocks of Derivatives Reporting
By Alan McIntyre, Regulatory Reporting Expert, Kaizen
After nearly three years of watching the Canadian Securities Administrators (CSA) craft their derivatives reporting rewrite, I’m convinced they’ve pulled off something remarkable: creating a regulatory framework that’s somehow both everything and nothing like its global cousins. It’s like watching someone order poutine with a side of fish and chips while sipping a margarita – technically it shouldn’t work, but here we are.
The Numbers Game: More Fields Than You Can Shake a Stick At
Let’s start with the obvious: field counts. The CFTC managed to slim down to a svelte 128 fields for their 2022 rewrite, clearly believing that less is more. ESMA, meanwhile, went full maximalist with 203 fields in EMIR Refit, apparently subscribing to the philosophy that if you’re going to ask for data, you might as well ask for everything including the kitchen sink and the recipe for the sandwich the trader ate during execution.
Enter Canada with 148 fields (up from their initially proposed 140), sitting comfortably in the middle like a regulatory Switzerland. It’s neither the American “keep it simple, stupid” approach nor the European “let’s document everything down to the thread count of the counterparty’s suit” methodology. It’s distinctly Canadian – polite, thorough, but not unreasonably so.
The UPI Situation: Taking Sides in the Global Divorce
Here’s where things get interesting. The CSA has decided to require Unique Product Identifiers (UPIs) for ALL asset classes, putting them firmly in the ESMA camp and leaving the CFTC looking like the odd one out at the derivatives reporting dinner party. The Americans are still dragging their feet on commodity UPIs like a teenager being asked to clean their room.
This creates a delicious regulatory arbitrage situation. Canadian firms reporting to multiple jurisdictions now get to experience the joy of generating UPIs for their commodity trades when reporting to Toronto, but not when reporting to Chicago. It’s like being asked to wear both a tie and a Hawaiian shirt to the same party – technically possible, but aesthetically questionable.
The Crypto Conundrum: Modern Problems, Modern Solutions
One area where the CSA has clearly been taking notes from ESMA’s homework is cryptocurrency derivatives. The inclusion of the “Derivative Based on Crypto-assets” field shows they’re thinking ahead – unlike the CFTC, which is still figuring out how to classify Bitcoin derivatives without causing an existential crisis in their taxonomy department.
This is smart regulatory future-proofing. Cryptocurrency derivatives aren’t going anywhere, and having a dedicated field for them prevents the current comedy of errors where firms report Bitcoin derivatives under the commodity asset class while secretly wondering if they should be filing them under “miscellaneous modern monetary confusion.”
The Timeline Tango: July 25, 2025
The CSA’s implementation date of July 25, 2025, is fascinating from a strategic perspective. It’s almost exactly 2.5 years after the CFTC’s December 2022 implementation, which means Canadian firms have had plenty of time to watch their American colleagues struggle through the transition, learn from their mistakes, and presumably stock up on coffee and antacids.
This timing also means the CSA Rewrite lands right in the middle of what I like to call the “global regulatory reporting fatigue zone” – that sweet spot where everyone’s tired of implementing new rules but not quite tired enough to stop making them.
The ISO 20022 Tease: The Gift That Keeps on Giving
Perhaps the most telling aspect of the CSA Rewrite is what it doesn’t include: ISO 20022. Like the CFTC, they’ve decided to save this particular joy for a future implementation, presumably sometime in 2026. This means we get to look forward to yet another round of system changes, testing, and the inevitable discovery that the ISO 20022 standard is both incredibly comprehensive and utterly bewildering.
It’s like promising to renovate your kitchen but deciding to do it in phases – first the cabinets, then the plumbing, then the electrical, ensuring maximum disruption over the longest possible timeframe.
The Goldilocks Effect: Just Right?
The CSA Rewrite represents something genuinely unique in the regulatory reporting landscape: a conscious attempt to cherry-pick the best elements from multiple jurisdictions while avoiding their worst excesses. It’s more comprehensive than the CFTC Rewrite but less overwhelming than EMIR Refit. It’s forward-looking on crypto assets but pragmatic about implementation timelines.
Whether this Goldilocks approach – not too hot, not too cold, but just right – actually works remains to be seen. What’s certain is that it creates a fascinating test case for whether regulatory compromise can produce better outcomes than regulatory extremes.
As we near July 25, 2025, one thing is clear: the Canadian approach to derivatives reporting reform is as distinctly Canadian as maple syrup on bacon – it shouldn’t work, but somehow it might just be brilliant.
Now, if you’ll excuse me, I need to go update my regulatory reporting calendar. Again.
- Stay tuned for Part 2 where human Alan fights back!
- For a conversation with Alan about the CSA Rewrite or a free health check of the quality of your reported data following the rewrite, please get in touch.
