August 8, 2014
Comments on Consultation Paper on Draft Regulations for Reporting of Foreign
Exchange Derivatives Contracts issued by the Monetary Authority of Singapore
Japanese Bankers Association

We, the Japanese Bankers Association (JBA), would like to express our gratitude forthis opportunity to comment on Consultation Paper on Draft Regulations for Reportingof Foreign Exchange Derivatives Contracts (the “Consultation Paper”) issued by theMonetary Authority of Singapore on July 9, 2014.
We respectfully expect that the following comments will contribute to your further
discussion on this issue.

1. Deferment of the application of Unique Transaction Identifier (UTI) reporting
requirement – (ANNEX) FIRST SCHEDULE PART I, 1. Contract information The Consultation Paper states that, for an uncleared contract that is notelectronically confirmed and is entered into on or after April 1, 2015, thecounterparties shall agree on the UTI to be reported. This requirement, however, isimplemented only in some jurisdictions. In particular, the process to agree on the UTI
for foreign exchange transactions is not standardized, especially in the Asian region.
Considering the current practices in some jurisdictions, the application of reporting
requirement of UTI agreed on with counterparties should be deferred until theprocess is standardized, although we think the process to agree on the UTI for foreignexchange transactions should be standardized in collaboration with authorities inrelevant countries and industry associations..
2. Definitions of information to be reported
For cross-border transactions, a single transaction may need to be reported tomultiple authorities, including those in Singapore, U.S. and Japan. The interpretationand views on the following information to be reported may differ across authorities.
Accordingly, we propose to unify the definitions of information to be reported basedon discussions among authorities, or to allow a certain level of flexibility forreporting entities to determine what to report.

1(i) Date of confirmation – (ANNEX) FIRST SCHEDULE PART IA, 2.
Confirmation Confirmation of contracts is carried out multiple times at the front and backoffices. Since the Securities and Futures Act sets the time for reporting as “within
2 business days”, or T+2, if the definition of “date of confirmation” is interpreted
as “the date on which the confirmation at the back office is completed”,confirmation of some transactions may not be completed by the specified
deadline.
The definition needs to be clarified to ensure the accuracy of reporting.
Therefore, we would like to confirm that the date of confirmation can beinterpreted as “the date on which the confirmation at the front office, not at theback office, is completed”.
(ii) Master agreement date – (ANNEX) FIRST SCHEDULE PART IA, 4.
Transactional data –This information is referred to as “Master agreement version” (optional) under
the EMIR, the European regulation, and “Master agreement date” (mandatory)
under the ASIC, the Australian regulation, resulting in differences acrossjurisdictions. With a view to reduce burden on reporting entities, the definition of
the same information should be unified.
For some assets subject to the reporting requirements, database does notcontain information on the date of contracts with counterparties, and considerable
time is required for database and systems development. In light of this, it isrequested to consider treating this information as an optional item or providing
lead time to reporting entities.
(iii) Hedging indicator – (ANNEX) FIRST SCHEDULE PART IA, 4.
Transactional data –If this information is to be included in the scope of reporting requirements, thedetailed definition needs to be provided to ensure the accuracy of reporting, since
this information is not required in other jurisdictions which have alreadycommenced the reporting of transactional data. Additionally, this should betreated as an optional item because this is not required in other regulations, andthe detailed definition is not specified.

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(iv) Exchange rate/Forward exchange rate – (ANNEX) FIRST SCHEDULE
PART IV, 1. Transactional data –Information to be reported for foreign exchange contracts includes (i)Exchange rate and (ii) Forward exchange rate. However, since the definitions ofthese are unclear, it is requested to specify the definitions.
The Securities and Futures Act defines “(i)” as the exchange rate of thecurrencies of the contract, and “(ii)” as the forward exchange rate on value date.
From these two definitions, it could be understood that same information (thesame rate) is required to be reported as separate information. Since “(ii) Forward
exchange rate” is calculated as the sum of spot rate and FX swap point, if “(i)Exchange rate” means a spot rate, this shall be explicitly defined. Moreover,other regulations such as the Dodd-Frank Act do not include the forward
exchange rate in the scope of information to be reported. In order to ensure
consistency with other regulations, this information should be treated as anoptional item.
3. Reporting commencement date – (ANNEX) SECOND SCHEDULE PART I 5.
Foreign exchange derivatives contracts booked in Singapore)
Taking into account the period required for systems development, someeight-month transitional period is necessary between the announcement of detailed
requirements and the reporting commencement date. Therefore, it is requested topromptly publish the final rules and the definitions of detailed data fields on
information to be reported through the DTCC, or to consider the deferment of thereporting commencement date.
4. Excluding the details of derivative contracts “Traded in Singapore” from thescope of information to be reported
Reporting of similar transactional data is already mandatory in many jurisdictions,and most of derivative contracts “Traded in Singapore” is reported to any relevant
regulators. For capturing the transaction volume and risks of entities located inSingapore, we consider it sufficient to require reporting of the details of derivativecontracts “Booked in Singapore”. Moreover, the current regulations in otherjurisdictions do not set forth similar requirements, and hence it is requested toconsider excluding the details of derivative contracts “Traded in Singapore” from thescope of reporting requirements.

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