MAS commences revised reporting requirements for OTC derivative contracts

On 5 July 2021, MAS issued a Consultation Paper on “Proposed Amendments to the Securities and Futures (Reporting of Derivative Contracts) Regulations” (“Consultation Paper”) to adopt changes to be aligned with technical guidance, published by the Committee on Payments and Market Infrastructures and the International Organisation of Securities Commissions (CPMI-IOSCO).

The revised requirements will take effect on 21 October 2024, and reporting entities will have approximately one year from now to prepare for these changes.

Key changes

1. Unique Transaction Identifier (“UTI”)

   • reporting entities must report a UTI assigned to each reportable contract
   • in order to provide further flexibility to reporting entities, the reporting guidelines will allow either the counterparties to the OTC derivative agreement, or even a third party, to generate the UTI code
   • responsibility for UTI generation follows the CPMI-IOSCO Waterfall steps
   • The UTI must remain consistent throughout the contract’s lifecycle and apply even when reporting occurs across various jurisdictions
   • reporting entities acting as agents must obtain UTIs from counterparties if no reporting obligation exists for the contract.

2. Changes to reportable data fields

   • MAS is adding new fields to align with other regimes globally
   • there are now 134 reportable fields
   • the complete list is available in Table 2 of the First Schedule of Annex D to the reporting guidelines where MAS includes information on acceptable values and which fields apply to each asset class.

3. Unique Product Identifier (“UPI”)

   • the purpose of the UPI is to denote a specific OTC derivatives product reported to a trade repository to facilitate global data aggregation of the specific product in the OTC derivatives market
   • a UPI code signifies a collection of specific values on the reference data elements which reside in the UPI Reference Data Library which went live in October 2023.

4. Collateral and margin

   • exemptions for reporting collateral and margin information by reporting entities will not be extended to fund/real estate investment trust (“REIT”) managers executing OTC derivative contracts on behalf of a fund/REIT that it manages
   • in cases where a fund/REIT manager is executing an OTC derivatives contracts for a portfolio that it does not manage, MAS views the fund/REIT manager’s role to be that of an agent and, would therefore not be required to report.

5. FX Swaps reporting

   • MAS requires the reporting of FX swaps as two separate contracts linked through the ‘FX Swap Link ID’ field
   • for other types of package trades, reporting entities should report the identifier linking the package trades under the “Package identifier” data field.

6. Existing contracts

   • MAS is of the view that re-reporting is necessary in order to improve data quality
   • any contracts that remain outstanding at the end of October 2024 that have a maturity date greater than six months from their commencement date will be required to be re-reported within two business days.

7. Transition to XML submissions

   • similar to standards applied elsewhere, Singapore derivative reporting submissions to trade repositories (TR) will be in the ISO 20022 XML format
   • this will replace current CSV or fPML formats currently being used.

How Waystone Compliance Solutions can help

Waystone Compliance Solutions has extensive experience assisting firms to navigate MAS compliance requirements. If you would like to discuss your reporting requirements in more detail, please reach out to our APAC compliance solutions team, or contact us.

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