The final phase of MAS reporting has finally come to pass, and all firm types in scope for MAS reporting are now required to report trades in all asset classes. Hopefully this shouldn’t be news for any affected firms, but there’s no time to sit back and relax, with MAS finally having joined the range of derivatives regulators looking to rewrite their rules.
MAS proposal: CDEs, UPIs, UTIs
The first consultation on enhancements to the MAS OTC derivatives reporting regulations is now closed, with proposals to introduce the global UTI, and many of the CDEs, in line with global harmonisation efforts, as well as introducing collateral and margin reporting, to come into effect in Q2 2023. MAS currently plans to implement the Unique Product Identifier (UPI) separately later on, despite the expected go-live of the UPI reference data system in July 2022, and so they’ve retained a wide range of product data elements that may quickly become redundant, sure to be a source of frustration if left unchanged in the final rules. We look forward to seeing what feedback firms have given and how MAS takes it on board.
Re-Reporting: a fresh start
Outside the content of trade reports, MAS has proposed the use of ISO 20022 XML for reporting, and has offered a variety of approaches to a global UTI generation waterfall to resolve the challenges of differences in cross-jurisdictional reporting deadlines. MAS has also proposed to require reporting counterparties to re-report all open trades above a minimum remaining maturity once the proposed reporting standards come into force, which is sure to be a pain for entities which have only just started reporting under the current rules to begin with.
Despite the pain that digging up new data on old trades is sure to cause, at Kaizen we know from experience looking at mixed RTS 1 and 2 EMIR reports that trying to squeeze trade reports from an old specification into a new structure following the rules update would result in messy, incoherent trade state data, so it makes perfect sense that MAS is mirroring ESMA in pushing to wipe the slate clean once they complete their rules rewrite.
Renewed focus on data quality
Mandating updates to old reports is a sure-fire indication that MAS is getting serious about data quality and reporting firms will want to ensure that they’ve captured any existing issues while they develop their new reporting framework, not to mention checking over their old reporting before they update open trades for the new requirements.