Planning for
APAC Trade Reporting
Rules Rewrites
SEPTEMBER 2023

Planning for APAC Trade Reporting
Rules Rewrites
The global trade reporting landscape is set for a shake up as the world’s most significant
derivatives regulations are being revisited with an eye towards improving data quality andharmonizing data standards and the adoption of revised and new fields, including CPMIIOSCO’s critical data elements (CDE) including the unique product identifier (UPI) and
implementing the ISO 20022 XML standard, amongst other changes. The industry is once
again faced with the dilemma of executing large-scale changes across multiple jurisdictionsin the next two years. Because of the magnitude of the changes, it is critical that adequate
planning and resources are available to support and meet the new regulatory requirements.
DTCC has been your strategic partner of choice since the inception of over-the-counter (OTC)
derivatives trade reporting – working with you to address your regulatory and operational
needs. We are ready to help you manage the complexities of the rules changes or “rewrites”
and are more than happy to discuss and address the compliance and implementation
challenges that you may face.
In the Asia-Pacific (APAC) region, regulators have been engaging with each other tocoordinate their derivatives reporting rule changes. The Australian Securities & Investments
Commission (ASIC) has publicly shared that regulators in Australia, Singapore, Japan, andHong Kong are focused on “maximum international alignment”, to improve data quality, andstrike an appropriate balance between commercial considerations, costs for the industry, andregulatory needs and outcomes. Timelines have also been coordinated, with the Financial
Services Agency of Japan (JFSA) going ahead with implementation on April 1, 2024 followed
by ASIC on October 21, 2024. The Monetary Authority of Singapore (MAS) is also expected toalign with ASIC and implement its rules rewrites in October 2024.

Global Trade Reporting Rewrites Roadmap› The industry may be impacted by the US moving to T+1 settlement on May 28, 2024.
›

Draft US Securities trade reporting rules may also impact the industry:
1. SEC SFT Reporting
2. OFR - Uncleared Repo Reporting

TBC

FINMA Rewrite5

TBC

HKMA Rewrite

TBC

NoA Phase 2: UPI (CO) & ISO 20022
Canada Additional Rewrite

TBC

REGULATORYRULE CHANGE
IMPLEMENTATIONGLOBAL DATASTANDARD
AVAILABILITY
1 NoA Rewrite = North America Rewrite

OCT

MAS Rewrite

21 OCT

ASIC Rewrite

2024

2023

UK-EMIR Refit

430 SEP

EU-EMIR Refit

3

29 APRJFSA Rewrite

1 APR

NoA Phase 2 Rewrite 2
UPI (RA, CR, FX, EQ)

29 JANUPI Expected Availability

16 OCT
1

2022

NoA Phase 1 Rewrite

5 DEC

ISO 20022

23 DEC

2 RA, CR, FX, EQ = Interest Rate, Credit,
Foreign Exchange, Equity

3 EU-EMIR Refit = European UnionEuropean Market Infrastructure
Regulation’s Regulatory Fitness andPerformance Programme

4 UK-EMIR Refit = United Kingdom-

European Market Infrastructure
Regulation’s Regulatory Fitness andPerformance Programme.

5 FINMA Rewrite = The Swiss Financial
Market Supervisory Authority RewriteIndustry Impacts

Based on our experience, you should consider the following when evaluating your readiness for the upcoming
APAC Rewrites:› Front to back processes, data requirements and lineage›

UPI implementation, including how UPIs will be exchanged at the point of trade execution and how the
information will be propagated downstream›

Re-Reporting including data requirements, when you will execute, and any required updates›

The impact of moving away from legacy messaging to ISO 20022 XML›

The impact to delegated reporting arrangements›

Collateral systems and how they will support the added complexity of reporting the entire set ofcollateral fields proposed for rewrites›

The need to create end-to-end test cases, including functional and technical specifications, to ensure
readiness for compliance›

The analysis, design and implementation of new business requirements and enhanced controls required
to adapt to the new rules›

An appropriate controls and incident management framework that is adjusted based on the rewrite
requirements

LET US HELP YOU GET READY FOR THE UPCOMING GLOBALREGULATORY CHANGES
Discover how DTCC, through our Global Trade Repository
service (GTR), DTCC Report Hub® and DTCC Consulting
Services, can help you address the significant data, technology,
and resourcing challenges associated with updating your tradereporting infrastructure and control frameworks for compliance with
the APAC Rewrites.

REACH OUT TODAYASIC Rewrite

ASIC published ASIC Derivative Transaction Rules (Reporting) 2024 on December 19, 2022.
These rules repeal and remake ASIC Derivative Transaction Rules (Reporting) 2022 on
October 21, 2024. The changes associated with the Rules Rewrite initiative will impact all fiveexisting reportable asset classes (Credit, Interest rates, Equities, Commodities, and Foreign
Exchange), Valuation, and Margin reporting. There are 104 data fields proposed by ASIC. Firms
will be required to submit in ISO XML 20022 format commencing October 21, 2024 and thetransition deadline to update existing trades is set for 6 months after April 20, 2025.

SUBMITTING DATA INTO THE TRADE REPOSITORYSUB TASK

KEY CONSIDERATIONS› October 21, 2024 – Amended Rules covering LEI, UTI,UPI, CDE fields, ISO XML and clean-up existing fields
that are not present in the rules and rollover exemptions.
Have you thought of how to report according to ASIC’s
Amended Rules?

NEW TECHNICAL STANDARDS AND VALIDATION RULES› The number of reportable fields has evolved to a new
set of data fields with the CDE adoption and global
harmonization. Have you completed the necessary gap
analysis on the new reportable fields?
› Do you have the relevant operational experience to map
data from your internal systems to appropriately
populate these new fields? If not have you consideredengaging external consultants?

CUTOVER TO THE NEW TECHNICAL STANDARDS› ASIC has indicated a six-month transition period
following publication of the Amended ASIC Rules
requiring data elements in transactions to be updated to
the new specifications and re-reporting of outstanding
legacy transactions with expiration dates after March 31,
2025. Do you have all the relevant data to update
historical trades according to the latest technicalstandards?
› Do you understand your counterparties’ intentions withregards to upgrading the open trade population?
› Have you thought about the reconciliation and controlsthat you need to implement during the transition period
to manage the newly reported versus legacy transitions?

USE OF XML: ISO 20022› ASIC has mandated to adopt ISO 20022 XML as theinbound message format. Have you considered how you
are going to generate XML files to submit into the TR?
› Do you have sufficient experience in-house to
implement the move to XML reporting?
› Do you require a CSV-to-XML converter?

VALUATION REPORTINGSUB TASK

KEY CONSIDERATIONSVALUATION REPORTING› Under ASIC Rewrite, firms now should submit their own
valuation instead of Central Counterparty valuation.
ASIC has added new fields for valuation reporting (i.e.,
Delta and Next floating reference reset date). Will yoursystem support reporting of these additional fields?

MARGIN REPORTINGSUB TASK

KEY CONSIDERATIONSMARGIN REPORTING› Currently, ASIC only requires the reporting of collateralvalue and collateral currency. Will your collateral systems
support the added complexity of reporting the entire setof collateral margin fields proposed for rewrite?

END-OF-DAY REPORTS
SUB TASK

KEY CONSIDERATIONS› Are the End of Day reports you receive today sufficient
for reporting parties to manage your data?

STANDARD SET OF END-OF-DAY REPORTS (TRADE ACTIVITY,
TRADE STATE, MARGIN ACTIVITY AND MARGIN STATEREPORTS)XML OR CSV REPORTING› ASIC does not mandate the format of the reports; hence
we will provide an option for both while some
proprietary DTCC reports will be csv only. These reports
will not be in the format of the current reports (i.e., thesubmission report, Trade State Report or Trade Activity
Report) that you receive today from DTCC, hence are
you ready to consume both CSV and XML reports?
› Have you considered any additional internal tooling youroperational teams may require?

KEY NEW FIELDSSUB TASKEVENT TYPE VERSUS ACTION TYPE AND MANAGING
LIFECYCLE EVENTSACTION TYPE: REVIVEKEY CONSIDERATIONS› ASIC has indicated that firms must now indicate theaction type and the event type, which is a significant
change to lifecycle event management. Have you
considered the implications to event choreography?
› The internal sources of these new event types may sit
across multiple applications. Have you mapped these
event types to application sources and determined how
these feeds reporting systems?
› Whilst not a new field, the action type “revive” has been
added to provide counterparties with the ability toreopen trades after being terminated or cancelled by
mistake. Are changes required in your reporting system
to account for reviving a previously closed trade?

SUB TASKUPIKEY CONSIDERATIONS› In the long term, the UPI should simplify reporting anddata aggregation as it reduces the number of reportable
fields. Have you considered how you will incorporate the
UPI into reporting applications?
› Have you considered if there needs to be UPI
components that should be submitted independently?
› Have you budgeted to pay for the UPI service?

PRIOR UTI

› Prior Unique Trade Identifiers (UTIs) provide entities theability to link transactions. Is the prior UTI obtainable fortrades that must be upgraded to the latest technicalstandards?
› Have you considered how you would link thesetransactions and any impact of sourcing the prior UTIs?
› Should prior UTI be used as temporary UTI if you
cannot obtain a UTI in time for reporting?

EVENT IDENTIFIER› The Event Identifier will be used to link trades that havebeen through an event such as a compression. Will allservice providers be able to provide this ID with
sufficient time to meet T+1 reporting?
› This field represents the entity responsible and legally
liable for reporting. If you are a reporting submitting
entity, have you considered the scenarios in which theentity responsible for reporting field is to be populated?

REPORTING ENTITY› In certain cases, the entity responsible for reporting fieldmust be populated with details of the fund managementcompany. If you are a reporting submitting entity, do you
have sufficient details of the fund managementcompany to facilitate this?

DIRECTION OF LEG 1 / LEG 2› As outlined in the final report, there are certaintransactions (i.e., equity swaps, FX swaps and FX
forwards) where the counterparties should determine
the payer and the receiver of each leg as determined at
the time of the transaction. Would this information be
stored for reporting trades that are open pre-ASIC
Amended Rules?

NOTIONAL SCHEDULE FIELDS (MULTIPLE)› Under ASIC Rewrite, reporting firms must report thenotional amount schedules up front. Have you
considered the implications for how to construct a
repeatable notional schedule?

SUB TASKKEY CONSIDERATIONSPACKAGE FIELDS (MULTIPLE)› Under ASIC Rewrite, the package spread must bereported, which may provide challenges if package
deals are booked as two separate trades. Have you
considered how you would book package deals in yourtrade capture systems?

DELTA› Under ASIC Rewrite, the delta must be reported. Have
you considered how this field will be reported?

REPORTING SIGNIFICANT ISSUES TO REGULATORY AUTHORITIESSUB TASK

KEY CONSIDERATIONSIDENTIFYING SIGNIFICANT ISSUES› Generally, when reporting parties experience significant
issues these must be reported to relevant supervisory
authority. Significant issues are defined as reporting
obstacles that prevent reporting, misreporting by areporting system flaw or an issue that causes a large
number of rejected reports. Is your Control Framework
sufficiently strong to ensure fast identification of“Significant Issues”?

SIGNIFICANT ISSUES IMPACTING OTHER REPORTINGPARTIES› Do your delegated reporting relationships have in place
the appropriate agreements and escalation procedures
to ensure “Significant Issues” are reported to theappropriate authority? This may include the Entity
Responsible for Reporting notifying their own regulatory
authority alongside the regulatory authority of theReporting Counterparty

RESOLVING SIGNIFICANT ISSUES› Underpinning this requirement for reporting parties to
notify the regulatory authorities of Significant Issues isthe enhanced focus on data quality. This means thatwhilst reporting parties must have the ability to identify
issues, they should also have the ability to remediatethem in a timely manner.
› If you use a vendor for your reporting, do you have theappropriate SLAs in place for incident identification andremediation?

MISCELLANEOUS
SUB TASK

KEY CONSIDERATIONSTHIRD-PARTY VIEWER› The third-party viewer field is a proprietary field and will
no longer be available when the ASIC Rewrite goes live
(due to XML schema restrictions). Have you considered
the alternatives for providing third parties access to yourdata?

TRANSACTION ID› The transaction ID field is a proprietary field and will nolonger be available when the ASIC Rewrite goes live
(due to XML schema restrictions). Have you determined
how this field is used by your firm?
› Have you considered any alternatives noting there are
no free format fields within ISO 20022 XML?

RESERVED FOR PARTICIPANT 1 – 5› The reserved for participant 1-5 fields are proprietary
fields and will no longer be available at the point ASIC
Rewrite goes live due to XML schema restrictions. Have
you determined how this field is used by your firm?
› Have you considered any alternatives noting there are
no free format fields within ISO 20022 XML?

MAS Rewrite

MAS started seeking views on the proposed amendments to the Securities and Futures(Reporting of Derivatives Contracts) Regulations 2013 in July 2021. Since then, MAS hascontinually engaged industry members and other APAC regulators before finalizing andpublishing its rules. The commencement date for the MAS reporting rules changes is
expected to be in October 2024 and confirmed via the second consultation response
published on May 16, 2023. In the proposed close-to-final rules, there are 134 reportable data
fields. ISO XML 20022 format is required for submissions when the rules commence, andre-reporting is to be within six months of rules commencement. There will be an exemption
for re-reporting of any information required for MAS Rewrites but previously was not captured
at the point when the contract was executed. No re-reporting is required for contracts with amaturity of less than six months from the commencement of rules.

SUBMITTING DATA INTO THE TRADE REPOSITORYSUB TASKNEW TECHNICAL STANDARDS AND VALIDATION RULES

CUTOVER TO THE NEW TECHNICAL STANDARDSKEY CONSIDERATIONS› The number of reportable fields has evolved to a new
set of data fields with the CDE adoption and global
harmonization. Have you completed the necessary gap
analysis on the new reportable fields?
› Do you have the relevant operational experience to map
data from internal systems to appropriately populatethese new fields? If not, have you considered engaging
with external consultants?
› MAS has indicated a six-month transition period upon
the commencement of the MAS Rewrite. MAS only
requires re-reporting when the contract has remaining
maturity of at least six months from the rules
commencement. However, where there is a change toany of the existing data fields until the contract matures,
expires, or is terminated, firms are required to continue toreport as per current requirement. Do you have all the
relevant data to update historical trades according to thelatest technical standards?
› Do you understand your counterparties’ intentions about
upgrading the open trade population?
› Have you thought about the reconciliation and controlsthat you need to implement during the transition period
to manage the newly reported versus legacy transitions?

USE OF XML: ISO 20022› MAS has mandated to adopt ISO 20022 XML as as theinbound message format. Have you considered how you
are going to generate XML files to submit into the TR?
› Do you have sufficient experience in-house to
implement the move to XML reporting?
› Do you require a CSV-to-XML converter?

VALUATION REPORTINGSUB TASK

KEY CONSIDERATIONSVALUATION REPORTING› Under MAS Rewrite, firms now should submit their own
valuation instead of central counterparty valuation. ASIC
has added new fields for valuation reporting (i.e., Delta
and Next floating reference reset date). Will your system
support reporting of these additional fields?

MARGIN REPORTINGSUB TASKMARGIN REPORTING

KEY CONSIDERATIONS› Currently, MAS does not fully require reporting ofcollateral. Will your system have the ability to report
new collateral margin fields proposed for rewrite?

END-OF-DAY REPORTS
SUB TASK

KEY CONSIDERATIONS› Are the End of Day reports you receive today sufficient
for reporting parties to manage your data?

STANDARD SET OF END-OF-DAY REPORTS (TRADE ACTIVITY,
TRADE STATE, MARGIN ACTIVITY AND MARGIN STATEREPORTS)XML OR CSV REPORTING› MAS does not mandate the format of the reports; hence
we will provide an option for both while some
proprietary DTCC reports will be csv only. These reports
will not be in the format of the current reports (i.e., thesubmission report, Trade State Report or Trade Activity
Report) that you receive today from DTCC, hence are
you ready to consume both CSV and XML reports?
› Have you considered any additional internal tooling thatyour operational teams may require?

KEY NEW FIELDSSUB TASKEVENT TYPE VERSUS ACTION TYPE AND MANAGING
LIFECYCLE EVENTSACTION TYPE: REVIVEKEY CONSIDERATIONS› MAS has indicated that firms must now indicate theaction type and the event type, which is a significant
change to lifecycle event management. Have you
considered the implications to event choreography?
› The internal sources of these new event types may sit
across multiple applications. Have you mapped these
event types to application sources and determined how
this feeds reporting systems?
› Whilst not a new field, the action type “revive” has been
added to provide counterparties with the ability toreopen trades after being terminated or cancelled by
mistake. Are changes required in your reporting system
to account for reviving a previously closed trade?

SUB TASKKEY CONSIDERATIONS› In the long term, the UPI should simplify reporting anddata aggregation as it reduces the number of reportable
fields. Have you considered how you will incorporate the
UPI into reporting applications?

UPI› Have you considered if there needs to be UPI
components that should be submitted independently,
e.g., asset class will not exist as individual fields anymore
and will that influence your downstream processes?
› Have you budgeted to pay for the UPI service?
› Prior UTIs provide entities the ability to link transactions.
Will prior UTI be obtainable for trades that must be
upgraded to the latest technical standards?

PRIOR UTI

› Have you considered how you would link thesetransactions and any impact of sourcing the prior UTIs?
› Should prior UTI be used as temporary UTI if you
cannot obtain a UTI in time for reporting?

EVENT TYPE

› The Event Type will be used to link trades that havebeen through an event such as a compression. Will allservice providers be able to provide this ID with
sufficient time to meet T+1 reporting?
› This field represents the entity responsible and legally
liable for reporting. If you are a reporting submitting
entity, have you considered the scenarios in which theentity responsible for reporting field is to be populated?

REPORTING SPECIFIED PERSON› In certain cases, the entity responsible for reporting fieldmust populate details of the fund managementcompany. If you are a reporting submitting entity, do you
have sufficient details of the fund managementcompany to facilitate this?

DIRECTION OF LEG 1 / LEG 2› As outlined in the final report, there are certaintransactions (i.e., equity swaps, FX swaps and FX
forwards) where the counterparties should determine
the payer and the receiver of each leg as determined at
the time of the transaction. Would this information be
stored for reporting trades that are open pre-MAS
Amended rules?

NOTIONAL SCHEDULE FIELDS (MULTIPLE)› Under the MAS Rewrite, firms must report the notionalamount schedules up front. Have you considered theimplications for how to construct a repeatable notionalschedule?

REPORTING SIGNIFICANT ISSUES TO REGULATORY AUTHORITIESSUB TASK

KEY CONSIDERATIONSIDENTIFYING SIGNIFICANT ISSUES› Generally, when reporting parties experience significant
issues, these must be reported to relevant supervisory
authority. Significant issues are defined as reporting
obstacles that prevent reporting, misreporting by areporting system flaw or an issue that causes a large
number of rejected reports. Is your Control Framework
sufficiently strong to ensure the fast identification of“Significant Issues”?

SIGNIFICANT ISSUES IMPACTING OTHER REPORTINGPARTIES› Do your delegated reporting relationships have in place
the appropriate agreements and escalation procedures toensure “Significant Issues” are reported to the appropriate
authority? This may include the Reporting Specified
Person notifying their own regulatory authority alongside
the regulatory authority of the Reporting Counterparty

RESOLVING SIGNIFICANT ISSUES› Underpinning this requirement for reporting parties to
notify the regulatory authorities of Significant Issues isthe enhanced focus on data quality. This means thatwhilst reporting parties must have the ability to identify
issues, they should also have the ability to remediatethem in a timely manner.
› If you use a vendor for your reporting, do you have theappropriate SLAs in place for incident identification andremediation?

MISCELLANEOUS
SUB TASK

KEY CONSIDERATIONSTHIRD-PARTY VIEWER› The third-party viewer field is a proprietary field and will nolonger be available when the MAS Rewrite goes live (dueto XML schema restrictions). Have you considered thealternatives for providing third parties access to your data?

TRANSACTION ID› The transaction ID field is a proprietary field and will nolonger be available when the MAS Rewrite goes live
(due to XML schema restrictions). Have you determined
how this field is used by your firm?
› Have you considered any alternatives noting there are
no free format fields within ISO 20022 XML?

RESERVED FOR PARTICIPANT 1 – 5› The reserved for participant 1-5 fields are proprietary
fields and will no longer be available when the MAS
Rewrite goes live (due to XML schema restrictions).
Have you determined how this field is used by your firm?
› Have you considered any alternatives noting there are
no free format fields within ISO 20022 XML?

HKMA Rewrite

The Hong Kong Monetary Authority (HKMA) is targeting to publish its consult for CDE
and UPI by the end of 2023. It has not made any announcement on regulatory timelines –with indication that implementation of revised trade reporting rules will not be earlier than
April 1, 2024. Collateral Reporting was initially scheduled to be implemented prior to theamended rules, HKMA and the Securities Futures Commission are now targeting to align theimplementation of Collateral Reporting with their rewrite.

The Challenges These Changes Create

These revamped trade reporting rules will create fresh challenges for market
participants in terms of aligning with new and differing regulatory reporting rules.
Challenges include:

CONSTANT REGULATORY CHANGE

COST PRESSURERESOURCE SKILLSET CHALLENGES

Inconsistent adoption of new datarequirements – including UTI, UPI, and ISO
20022 messaging – by regulators will require
firms to continually reassess and update
their trade reporting technology processes
as the changes roll out. Compliance isand will remain a moving target, with
failure potentially leading to penalties andreputational damage.

Operating and maintaining internal tradereporting systems is expensive. The costof continuously updating infrastructure toaccommodate differing reporting timelines
and requirements will be even greater,
especially if approached in a tactical versus
strategic manner.

Sourcing regulatory reporting expertiseto meet multiple different jurisdictional
reporting requirements is challenging
for firms.

HOW DTCC CAN HELP ALLEVIATE THE PRE & POST REPORTING BURDEN WITH DTCC REPORT HUB
When it comes to your reporting infrastructure, controls,
and processes, consider finding a service that delivers
the greatest value and readies you for the regulatorychanges taking effect in the next few years. The DTCC
Report Hub® service is a highly efficient pre and post
trade reporting solution that can help manage thecomplexities of meeting multiple regulatory mandates
across jurisdictions. With comprehensive jurisdictionaland regulation coverage, the service can help you
to mitigate compliance risks, enhance operational
efficiencies and drive down costs.

LET THE POST-TRADE EXPERTS HELP YOU TRANSFORM YOURREPORTING CONTROL FRAMEWORKIn addition, you can tap into our expertise to help you tackle your reporting challenges andassist in getting you ready for your compliance reporting. Our DTCC Consulting Services
is uniquely positioned to provide firms with consulting services that tap into the breadthand depth of our experience to help you transform your post-trade business operations,increase efficiencies, reduce risks, and drive down costs. For 50 years, our clients havetrusted us to solve some of the biggest issues facing the global financial services industry.
This unique vantage point has enabled us, through DTCC’s family of companies, todevelop techniques and tools that can help firms drive innovation and transformation.
With the help of our post-trade experts, we can help you address these challenges andhelp you get ready for the swathe of regulatory changes, including APAC Rewrites, taking
effect over the next few years. DTCC Consulting Services experts leverage our proprietary
Reporting Control Framework Model to conduct a deep-dive diagnosis and propose an
implementation plan to enable you to enhance your reporting processes by aiming toincrease operational efficiencies, drive down costs, and mitigate risks.

DTCC CONSULTING SERVICESOUR EXPERTISE. YOUR ORGANIZATION.

FOR MORE INFORMATION

Links to other resources:› Planning for EMIR Refit› Planning for JFSA Trade Reporting
Rule Rewrite

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