Research Report – 2014/001.1a
Updated 23rd April 2014
European Commodity Market Regulations
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European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
European Commodity Market Regulations Part 1
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Increased regulation and oversight of European energy and commodity trading has commenced as various aspects of the EMIR (European Market Infrastructure Regulation), REMIT (Regulation on wholesale Energy Market Integrity and Transparency), and other regulations start to bite. These regulations are already having an impact on trading and risk management business practices and may have far reaching and as yet, even un-thought of consequences for the industry. Unfortunately, the authorities have yet to define some of the detail and clarity needed to be able to determine this.

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European Commodity Market Regulations Part 1

  1. 1. Research Report – 2014/001.1a Updated 23rd April 2014 European Commodity Market Regulations Implementation, Impacts and Solutions Part 1 of 2 Sponsored by
  2. 2. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 2 Contents Introduction....................................................................................................................................................5 Big Compliance comes to Energy Trading.......................................................................................................6 Background.....................................................................................................................................................7 The Banking crisis of 2007/2008.................................................................................................................7 MiFID II........................................................................................................................................................7 Basle III/CRD IV ...........................................................................................................................................8 The EU “Third Package” and REMIT............................................................................................................8 Key Themes.....................................................................................................................................................8 EMIR Rules Overview....................................................................................................................................10 Different types of party under EMIR ........................................................................................................10 REMIT Rules Overview..................................................................................................................................11 Timings..........................................................................................................................................................12 The EMIR Threshold for Non-Financial Counterparties................................................................................13 Threshold calculation................................................................................................................................13 Trade Reporting............................................................................................................................................15 Trade Reporting for EMIR.........................................................................................................................15 What must be reported?......................................................................................................................15 Where data should be reported?.........................................................................................................15 Which data must be reported? ............................................................................................................15 When should data be reported? ..........................................................................................................16 Backloading ..........................................................................................................................................16 Trade Reporting for REMIT.......................................................................................................................16 Which data must be reported? ............................................................................................................16 Where should data be reported?.........................................................................................................17 What data types must be reported? ....................................................................................................17 Non Standard Trades............................................................................................................................19 Data Destinations .....................................................................................................................................19 Implementing a trade reporting solution.................................................................................................21 Solution types.......................................................................................................................................21 Required Solution Activities......................................................................................................................22 Data sourcing and gap analysis ............................................................................................................22 Data mapping and capture...................................................................................................................22 Configuration choice and connection mechanism...............................................................................22 Data enrichment...................................................................................................................................22
  3. 3. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 3 Pre trade data.......................................................................................................................................22 Issues being encountered.........................................................................................................................23 LEIs (Legal Entity Identifiers) ................................................................................................................23 The UTI (Unique Trade Identifier).........................................................................................................23 Which rules apply to a trade?...............................................................................................................24 Changing requirements........................................................................................................................24 Risk Management .........................................................................................................................................25 Timely confirmation..................................................................................................................................26 Portfolio Reconciliation and Dispute Resolution......................................................................................26 The reconciliation process........................................................................................................................26 Typical modes of operation..................................................................................................................26 Bilateral reconciliation..........................................................................................................................27 Third Party Service Provider.................................................................................................................27 Agent ....................................................................................................................................................27 Contractual Changes required for Portfolio Reconciliation and dispute resolution ............................27 Portfolio Compression..........................................................................................................................28 Bilateral Compression...........................................................................................................................28 Multilateral Compression.....................................................................................................................28 Is it worth compressing if it is not mandatory?....................................................................................29 Daily mark to market/model................................................................................................................29 European Regulatory Solutions Directory ....................................................................................................30 Types of service and software..................................................................................................................30 Trade Repositories................................................................................................................................30 Reporting Services................................................................................................................................35 NASDAQ OMV.......................................................................................................................................35 Specialist Reporting and aggregation software....................................................................................37 E/CTRM offerings..................................................................................................................................44 Portfolio Reconciliation/Dispute Resolution........................................................................................47 Portfolio Compression..........................................................................................................................48 TriOptima triReduce.............................................................................................................................48 Trade Surveillance ................................................................................................................................49 About The Authors........................................................................................................................................52 Aviv Handler..............................................................................................................................................52 Dr. Gary M. Vasey.....................................................................................................................................52 ComTech Advisory....................................................................................................................................53 ETR Advisory .............................................................................................................................................53
  4. 4. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 4 About the Sponsor........................................................................................................................................54 TriOptima..................................................................................................................................................54
  5. 5. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 5 Introduction Increased regulation and oversight of European energy and commodity trading has commenced as various aspects of the EMIR (European Market Infrastructure Regulation), REMIT (Regulation on wholesale Energy Market Integrity and Transparency), and other regulations start to bite, with Trade Reporting under EMIR going live on February 12th 2014. The regulations are already having an impact on trading and risk management business practices and may have far reaching and as yet, even un- thought of consequences for the industry. Despite several go live dates having passed, there is still a lack of clarity over many of the details. This has left a trail of confusion in the wake of the rule roll out. The Trade Reporting go live was but one milestone in the many that await the energy and commodity trading industry. REMIT, mandatory clearing, MiFID II and others will follow in the not too distant future. And as with the rules we have already seen there is a great deal of confusion about scope, applicability and detail. This research, conducted jointly by industry leading analysts and experts, Commodity Technology Advisory and ETR Advisory, aims to help to clarify the issues and to examine the impact of regulation on software requirements in the trading and risk management business function. It looks at the current implementation schedule of the regulations and examines some of the implementation impacts of the yet to be defined details of the regulations. It also reviews the software, services and platforms available in the market to support aspects of the European regulatory environment and establish the readiness of European traders for operating under the regulations. The research is focused on understanding: Implementation time frames and what this means to traders The unknowns and yet to be defined details and their implications as the rules are rolled out A review of solutions, services and platforms in the market designed to support these regulations, including how the solutions offered for EMIR reporting fared during the go live Readiness of trading organizations from a business process, technology and holistic standpoint – This is a separate report. This report is an updated version of the original written in the second half of 2013. It adds notes of post go live reality, and also updates on the next regulations to be implemented.
  6. 6. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 6 Big Compliance comes to Energy Trading The energy and broader commodity-trading world is in the process of its latest stage in its maturity: That of “Big Compliance”. The rules that most energy traders will have to implement not only require a great deal of IT work, but also some process re-engineering and an acceptance of the fact that compliance will occupy a significantly larger component of overall activities and budgets on an on-going basis. One can argue as to whether this is appropriate for an industry that many feel is “non-systemic”, but as things stand most of these changes will happen with the result that industry business processes, practices, the IT landscape and possibly even the players, will change. The Trade Reporting go live underlines this point. While the “big bang” IT project could be considered to be heading towards the “stabilization” phase, it is expected that many more changes will come. And after that, we expect the Financial Stability Board (FSB) review of Trade reporting implementation to require more re work. This is clearly therefore simply the start of an ongoing stream of work. Advertisement
  7. 7. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 7 Background The upcoming rule sets stem initially from two sources: 1) Reactions to the Banking crisis of 2007/2008 2) The EU “3rd Package” - which further aims to create a single European gas and power market. The Banking crisis of 2007/2008 Following the crisis, several initiatives kicked off in order to attempt prevention of a repeat. Key amongst these was the declaration that arose out of the 2009 G20 Pittsburgh Summit, which stated: “All standardized OTC derivative contracts should be traded on exchanges or electronic trading platforms, where appropriate, and cleared through central counterparties by end‐ 2012 at the latest. OTC derivative contracts should be reported to trade repositories. Non‐ centrally cleared contracts should be subject to higher capital requirements.” In essence, the objective of this declaration was a reduction in the “systemic risk” that brought the crisis about. Each G20 country undertook to conform to the declaration, and this has resulted in several initiatives including Dodd Frank in the US, and EMIR (European Marketing Infrastructure Regulation) in the EU. Other G20 countries are also in the process of implementing their versions. Amongst the principles encompassed in the declaration, were: - Transparency - Move to standardized exchanges - Risk reduction These have led to a variety of pillars including reporting of trades to repositories, a move to OTC Clearing, several risk reduction techniques and the desired imposition of mandatory position limits on commodities. MiFID II In addition to EMIR, other initiatives were created in order to address the issues. In Europe, this includes MiFID II. The Markets in Financial Instruments Directive (MiFID) came into force in 2007 and introduced several new concepts for financial companies, such as “passporting” i.e. the requirement to be able to execute equally in any European location, and a requirement to provide best execution. It introduced the concept of a Multilateral Trading Facility (MTF) to which certain transparency and operation rules apply. However, the majority of commodity traders received an exemption from these rules. MiFID II extends the original initiative in many ways, including a wider ranging Organized Trading Facility (OTF). Of particular interest to our market are three items: 1) The potential narrowing of the commodity trader exemption, in many cases, 2) The widening of the scope of what a derivative is, bringing more physical trades into the threshold calculation 3) Mandatory Position Limits (which in the US are being implemented within Dodd Frank).
  8. 8. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 8 The result of some of the above will mean that more energy traders will find themselves either needing to or wanting to obtain MiFID licenses, thereby turning them into Financial Counterparties. That in itself has consequences including the introduction of mandatory clearing. Basle III/CRD IV The Basle III accords modify the Basle II accords targeted at the banking industry. These outline how banks should calculate their capital requirements, for credit, market and operational risk, amongst other things. Basle III moves to a more prudent capital calculation methodology and capital ratios for banks. This includes the use of Credit Value Adjustment (CVA) and similar measures. In Europe, the rules are being implemented as the fourth Capital Requirements Directive (CRD). It also requires extra reporting such as COREP. Some of the new capital calculation rules could well apply to energy traders, although probably not until 2017. However, these are yet another set of rules that should be on Energy Traders’ radars, especially if they obtain MiFID licenses, which brings CRD IV straight into scope. The EU “Third Package” and REMIT The European Union third package was adopted in 2009. It aimed to further open up Europe’s gas and power markets using several means including unbundling previously vertically integrated gas and power companies, the move to standardize TSOs, and the creation of a single market. As part of this framework, the Regulation of Wholesale Markets Transparency and Integrity (REMIT) aims to increase transparency within the market, by the prohibition of insider trading, and aims to further limit market abuse. The prohibition of market abuse involves not only avoiding attempted and actual market manipulation, but also reporting trade and “fundamental” data to the authorities. REMIT applies to all wholesale physical Gas, Power, LNG and Emission trading in Europe as well as to connected derivatives. Key Themes There are four key “themes” identifiable across all of these new initiatives and these are explored in the body of this report: - Trade and Position Reporting – reporting of trades under EMIR and REMIT and also position reporting under MiFID II - Clearing - OTC Clearing as mandated under EMIR - Risk Management – Rules such as Portfolio reconciliation and compression under EMIR as well as CRD IV rules - Trade Monitoring and Surveillance – Under REMIT as well as MAD II
  9. 9. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 9 The table above summarizes the regulations and the four key themes. Although linked, each stream requires a different set of process and IT changes. We will be addressing them separately, with this particular report focused on trade reporting and risk management. Advertisement unified app emir remit mifid II / mifir mad.... interfacing seamless upload etrm/pms trading platforms multiple formats static data counterparty agreements repository delegation uti define rules generate consume update flexible mapping data enrichment reporting rollback/resubmit portfolio reconciliation bilateral third party as-a-service Gotenstrasse 13 · 68259 Mannheim · Germany Tel : +49 (621) 319 55030 Fax : +49 (621) 319 55031 e-Mail : info.eopt@eopt.org secure in-house data audit logging archive data features multi-tenant fully automated on-behalf reporting mismatch details PriceHub e·Comply The Complete Compliance Solution Reporting Clearing Risk Management Trade Monitoring EMIR To Trade Repositories To applicable OTC derivatives for FC and NFC+ Timely Confirmation Portfolio, Reconciliation, Dispute Resolution, Portfolio Compression, Daily mark to market (FC, NFC+) REMIT Power and gas physical and financial to RRMs Fundamental data to RISs None manipulation rules apply to physical and financial gas and power MiFID II Real time position reporting and limits various MAD II Extends MAD
  10. 10. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 10 EMIR Rules Overview As outlined above, EMIR is based on the declaration at the G20 Summit in Pittsburgh in 2009. It entered into force on 16 August 2012. The European Securities Market Authority (ESMA) implements EMIR, and the local National Compliance Authorities (NCAs), such as the UK FCA, enforce it. The Regulatory Technical Standards to implement many of the rules were proposed in December 2012 and subsequently approved by the European parliament in February 2013. EMIR has four key themes: Trade Reporting – This requires all derivatives (OTC and Exchange Traded) to be reported to third party “Trade Repositories” (TR). Both sides of the deal must report the trade using the same identifier, within T+1. This requirement commenced on 12th February 2014 for all OTC derivatives. Clearing of OTC Derivatives – It is desired that as many OTC derivatives as possible are cleared via CCPs. This will generally apply to more standardized derivatives. There will also be new rules about the margin requirements of uncleared derivatives but these are not yet finalized. Risk Mitigation – Five sets of rules designed to mitigate risk: Timely Confirmations, Portfolio Reconciliation, Dispute Resolution, Portfolio Compression, and Daily Mark to Market/Model. These rules are explained in more detail in the section below. CCPs (Central Clearing Counterparties) – Rules about the running and funding of CCPs that are not relevant to the Energy Trading business. However as Energy and Commodity Traders get pulled into the world of clearing it will be important for all to be familiar with how CCPs operate. Different types of party under EMIR EMIR defines four types of party: 1) Financial Counterparties (FC) such as banks and other financial institutions 2) Non-Financial Counterparties (NFC) – all other EU-based entities. These are divided into: a. Over the “threshold” (NFC+) - those who trade over a certain amount per year b. Under the “threshold” (NFC-) 3) Third country – those outside the EU NFCs must determine their status by using a different threshold number for each asset class as follows: Credit - €1bn Equity - €1bn Interest Rates - €3bn FX - €3bn Commodities €3bn The numbers above refer to annual gross notional numbers. Only “unhedged” trades are to be included in this number. Only one of these numbers must be breached in order for the trading entity to be considered “over the threshold”.
  11. 11. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 11 It has been obligatory to report being over the threshold since 15th March 2013. All market participants are obligated to be calculating their totals on a daily basis, using a 30-day average. Those under the threshold have a more lenient interpretation of the rules, as will be outlined below. The way that thresholds have been calculated across the industry seems to vary. Not only have ESMA issued new advise several time over the last few months, in the form of Questions and Answers documents, but there appears to still be room for a great deal of interpretation, especially in commodities and energy. Until clarity is obtained it is expected that there will be a great deal of confusion in this area. REMIT Rules Overview The objective of REMIT is to promote market integrity and transparency in the European gas and power markets, and it entered into force in December 2011. The EU-level Agency for the Cooperation of Energy Regulators (ACER) are responsible for implementing the rules with local National Regulatory Authorities (NRAs) enforcing them by implementing national laws. It applies to all physical wholesale gas, power, LNG and emission trading in Europe, and derivatives based on them. REMIT is an EU level “Regulation”, which each country must implement. ACER publishes “guidance” on how it thinks the rules should be implemented but these are non-binding. REMIT has two pillars: Inside Information – From December 2011 it was prohibited to trade using inside information. The information in scope relates to physical information that could be used to the receiving party's advantage, such as knowledge of an unplanned outage. If in possession of such information, market participants may only trade under very limited circumstances. The approach to compliance so far has been to publish the information as soon as possible usually on a company website (known as the “REMIT Page”). The information can also be published to transparency platforms managed by certain parties, such as the National Grid in the UK. Prohibition of Market Manipulation - Once REMIT is “implemented” by the European parliament, it will be prohibited to attempt to or actually manipulate the markets. The ACER guidance contains many details of what comprises market manipulation, divided into: a) false or misleading transactions, b) price positioning c) transactions involving deception and, d) dissemination of misleading information. In addition to prohibiting this activity, REMIT requires that all trade and fundamental data be reported to ACER 6 months after the rules come in. This gives rise to the second trade-reporting requirement, which is outlined in the section below.
  12. 12. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 12 Timings This diagram summarizes the various timings of EMIR, REMIT and MiFID II:- 15th March 2013 Daily Threshold Calculation Confirms T+7/5 15th Sept 2013 Portfolio Reconciliation Dispute Resolution Compression 12th February 2014 EMIR Trade Reporting 12th May 2014 EMIR Backloading (Trades after 16th August 2012) Q3 to Q1 2015 OTC Clearing for FCs 15th September 2014 Remaining EMIR Risk Management Q2 REMIT “Implemented Q4 REMIT Reporting (Standard Trades) Jan 2016 Beginning of MiFID II implementation. The timetable above shows a summary of the dates as at the time of writing. However, it is worth noting that many of these dates, particularly for trade reporting, have slipped and some could slip again. For example, REMIT was originally to be implemented in June 2013. However this has not yet occurred at the time of writing. Implementation is now expected in Q2 2014. Reporting is to start 6 months after implementation. However, this would require that the infrastructure is ready. We recommend that participants keep a close eye on developments.
  13. 13. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 13 The EMIR Threshold for Non-Financial Counterparties Non-financial counterparties that are over the threshold must bear more onerous requirements than those that are under, as summarized in this chart: NFC- NFC+- Trade Reporting All trades to be reported All trades to be reported including daily market to mark information and collateral information Clearing OTC Clearing not mandatory OTC Clearing Mandatory Timely Trade Confirmations Currently must confirm within T+4 going to down T+2 in August 2014 Currently must confirm within T+2 going to down T+1 in August 2014 Portfolio Reconciliation Must reconcile either quarterly or annually depending on size of portfolio Must reconcile daily, weekly or quarterly depending on size of portfolio Portfolio Compression Must compress trades for portfolios with over 500 trades Must compress trades for portfolios with over 500 trades Daily Mark to market Not required Must mark to market or model daily. The requirement to clear, when it comes in, could require a great deal of extra capital from the market participants, Therefore, many market participants consider it to be desirable to be under the threshold. Threshold calculation Since 15th March 2013, it has been obligatory for NFCs to calculate their threshold values on a daily basis using a 30-day average, and to report to the NCA if over. In order to be considered to be over the threshold, a market participant needs to be over one of the following: Credit - €1bn Equity - €1bn Interest Rates - €3bn FX - €3bn Commodities €3bn The gross notional value of the balance of each number is taken. There are however, some important considerations: Group level calculation – The value to be used is the total for all entities in the group, no matter where they are. Therefore, a small subsidiary of a large non-EU group could find itself over the threshold. The participant must calculate each number for each group member and sum those on a gross basis to see if they are over. If the group company is in a third country, which is a “recognised regime”, that total may not need to be included.
  14. 14. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 14 Hedges – Hedged trades do not contribute to the threshold. Hedges under EMIR are defined as a trade being one of the following: a) The trade is already defined as a hedge under hedge accounting rules (e.g. IAS 39) b) It is designed to objectively “reduce risk” of assets, services, inputs, products, commodities or liabilities that the NFC owns c) It is designed to reduce the risk of a hedge instrument as defined above It is important to record the hedge status of each trade to determine if it is a hedge or not. NCAs are already auditing NFCs that are not over the threshold and so it is important to record the hedge reason. What is a derivative? – When calculating the threshold it is important to consider which trades are considered “derivatives” under EMIR. A derivative under EMIR is in fact defined under MiFID Annex C. This definition is not simple but is generally defined as a trade that is settled for cash, but also as a trade that is transacted via a multilateral trading facility (MTF), which is particularly important for physical forwards, which could otherwise not be considered thus. Different execution venues, platforms and brokers may or may not be MTFs, and there is a current trend for certain platforms to delist themselves from the MTF list. Since the list will be dynamic, any solution to calculate threshold values will need to be able to cope with such changes It is also worth noting that many brokers are offering both “MTF” and “Non” MTF execution paths, with trading gateways often offering routes to brokers via both methods. There is also confusion over what a “physical” trade is – must it be physically settled, or does it count if it could be physically settled? The different clauses of MIFID Annex C have different wordings. Because of all of this confusion, on February 14th ESMA wrote to the European Commission asking for clarification on this topic (as well as FX Forwards). Until then, ESMA have been heard to say that they will not be enforcing the reporting of physical trades under EMIR. If an intra-group trade is not a hedge (although it often will be), then both sides of the trade count towards the threshold i.e. double the notional.
  15. 15. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 15 Trade Reporting EMIR and REMIT each have trade reporting requirements: EMIR for OTC and Exchange Traded Derivatives, and REMIT for physical wholesale gas power, LNG and emissions trades as well as their derivatives. EMIR Trade reporting started in February 2014, with REMIT due in Q4 2014. REMIT specifically has a goal of “avoidance of double reporting” which is intended to remove the need to send any data twice under both EMIR and REMIT. This is turning out to be difficult in practice. In this section, we will first examine the trade reporting requirements of each rule set and then bring them together. Trade Reporting for EMIR What must be reported? EMIR requires all derivatives trades to be reported, by any party transacting them. This is in contrast with Dodd Frank in two key ways: 1) Dodd Frank only requires OTC trades to be reported, EMIR requires Exchange Traded deals (ETD) as well 2) Both sides of the trade must report, using the same Unique Trade Identifier (UTI). In some cases exchange traded deals can be reported by the exchanges themselves, or by clearing brokers (for a fee). However, the obligation to report remains with the market participant. Lack of clarity about this issue, and about which Entity IDs to put into certain fields, led to a request by ESMA to delay reporting until 2015. However, this was denied by the European Commission. The last minute introduction of such reporting has led to a great deal of confusion, which has still not been resolved. When deciding what a derivative is, careful consideration must be given to the type of instrument and where it is executed. This is discussed in more detail in the “calculating the threshold “section. Where data should be reported? EMIR trade data must be reported to a registered “Trade Repository” (TR), a third party who will make the data available to ESMA runs a trade repository. Several entities are approved as TRs at the time of writing and most are detailed in the services catalogue at the end of this report. When reporting, market participants can either send data straight to TRs, get someone else to do it on their behalf, or send the data via “Reporting Services”. All of these options are considered in the services directory at the end of this report. Which data must be reported? Detailed data differs per asset class. However, the data can be divided into the following categories: Entity Identification – Of the parties involved in the trade. Will include the reporting entity, counterparty and others such as the beneficiary (if not the counterparty) broker etc. Contract Information - Information about the deal and contract, including where it was executed. UPIs preferred. Could require a complex product type derivation. Transaction Information – Trade level details such as quantity, notional etc., requires the Unique Trade Identifier.
  16. 16. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 16 Trade Type Specific Information - Different sets of fields for IR, FX, and Commodity etc. Commodity profiles are multi record. Option Information - Strike, call or put, etc. Confirm Information – About the trade confirmation. Clearing Information – Including the Clearer ID and time of clearing. Status – “New/modify/cancel/termination/compression/valuation update/other.” – Each time a trade changes it must be resent with a new status. In addition to the above, FCs and NFC+s must report collateral and valuation information on a daily basis. However, this reporting will only start 6-months after the initial reporting i.e. on 12th August 2014. Some details of this data are examined in the “realities of implementation” section below. When should data be reported? Data typically should be reported to a repository by the end of the next working day. This includes when some of the data, such as the confirmation data, is missing. It should be sent later in an update. Trades executed after 4pm count as the next day’s trades in terms of measuring T+1. Backloading EMIR came into force on 16th August 2012. This means that any data on trades in existence then must also be reported or “backloaded” to repositories. By implication, it is important to locate this data as soon as possible. Backloading is required in several stages: Trades still open on the first reporting date (i.e. February 12th 2014) executed after 16th August, 2012 – upon go live (12th February 2014) Trades still open on the first reporting date (i.e. February 12th 2014) executed before 16th August, 2012 – 3 months later (i.e. May 12th 2014) - although most backloaded these on go live Trades executed after August 16th 2012 but that matured before the first reporting date- 3 years after reporting date Trade executed before August 16th 2012 but that were still open on 16th August 2012 – 3 years after reporting. Trade Reporting for REMIT Which data must be reported? REMIT reporting falls into the following two categories at the highest level: Trade Data – Data related to trades and orders Fundamental Data – Data related to the physical state of the grid, e.g. outages, loads, etc. Here we focus on trade data. REMIT covers Physical Power, Gas, LNG and Emissions, as well as their related derivatives. Technically, therefore some of the derivatives will fall under both REMIT and EMIR. However, ACER has put forth a principle of the “avoidance of double reporting”. In theory, this means that if you report data under EMIR you do not have to report it again under REMIT. However, since REMIT
  17. 17. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 17 requires additional data elements to EMIR, it is not yet clear how and if this will work in practice. Each version of the draft implementing Act has seen a different approach proposed and so the market will need to wait for a final version in order to work out how to address this. Where should data be reported? ACER will be collecting all of the reported data and using it to monitor the market for abuse. A system called “ARIS” (ACER’s Regulatory Information System) is being built for this purpose. Because of the large number of market participants, ACER do not wish for data to be sent to them directly, instead, they need to be sent via intermediaries called “Registered Reporting Mechanisms (RRMs). These third party facilities will each have their own way of collecting the data and forwarding it to ACER. An EMIR TR could also be an RRM, or it may not be one. An RRM that is not a TR could forward the data to the TR as well, or they may not. This is discussed in the “Data Destinations” section. What data types must be reported? REMIT requires pre trade data, i.e. order information, to be reported as well as trade data through the lifecycle. The order information includes orders for unexecuted deals. REMIT defines four “Data Views” which different data elements required within each view. These are: - Order view – Elements required to be sent when an order record is sent - Execution view – Elements required to be sent when a trade is executed - Confirmation/Clearing – Elements required to be sent when a trade is confirmed and/or cleared - Non Standard View – Elements required for a complex “nonstandard” trade (see below)
  18. 18. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 18 The data elements can be summarized by this table: Order Execution Clearing /Confirm Non Standard Identification Of the various parties, including broker etc. Likely to require LEIs. Includes market place ID P x x x Contract Info about the deal and contract, including where it was executed. UPIs preferred, Could require a complex taxonomy p x x Order Order Type (Market, Limit etc.,) x Transaction Trade level details such as quantity, notional etc. + UTI p x x p+ PDF Trade type specific info Different sets of fields for IR, FX, and Commodity etc. For commodity profiles are multi record. Includes physical data x x Option Info Strike etc. x x Confirm Info When confirmed, details to be filled in Clearing Info When confirmed, details to be filled in x Status New/Split/Modify/Cancel/ Terminate/Other x x x x The full field list is found in the document on the ACER website at http://www.acer.europa.eu/remit/Documents/Recommendations%20on%20REMIT%20Records%20 of%20transactions.pdf
  19. 19. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 19 Non Standard Trades For trades that are considered “complex”, it is only necessary to send a subset of 23 data elements. In addition, there is a requirement to send a PDF scan of the contract to ACER. Details about how this will work, and also about which trades are defined as non-standard are not yet known. Data Destinations Ultimately, EMIR data must reach a Trade Repository, and REMIT data must reach an RRM. However, there are several different combinations and services available: 1) TR Only – Some EMIR TRs will only accept EMIR data. If choosing one of these, it will also be necessary to send data to an RRM separately 2) RRM Only – Similarly some RRMs will only accept REMIT data 3) TRs that are also RRMs – some TRs have committed to becoming RRMs 4) RRMs that forward to TRs – some prospective RRMs will accept all data and forward the data to an EMIR RRM 5) Reporting services – Some third party services are planned that will take in all of the data and report it to both TRs and RRMs Advertisement
  20. 20. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 20
  21. 21. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 21 Implementing a trade reporting solution Solution types Every market participant is required to implement a trade reporting solution in some form. This may be very simple, for example uploading a trade spreadsheet to a repository, or it may require a large amount of engineering, for example for a multi-site market participant with several ETRMs. It is also possible to delegate the reporting to another party, or several parties. There are several different types of configuration available, which can be summarized by these levels: Level Key features Pros and cons Typical participant type Delegated Another party reports on the market participant’s behalf, This can either be as a specialized service or in some cases for a set of deals, for example, an exchange reporting all trades executed there, or pre trades for REMIT. + Less work for participant + Less prone to error -No audit log for participant - Could be expensive. - Participant is still liable for errors Small traders, or as a partial solution for any type Manual A manual spreadsheet/csv upload to a repository or reporting service. Some repositories will offer on screen trade entry. +Easy to use for smaller traders +Good way to send trades already in spreadsheets even for larger players -Lack of auditability -Prone to error Small participant with few trades or as a partial solution for larger participants Outsourced Duty of reporting outsourced to another party. The party will either have the most of data already, or provide a simple mechanism to take the data The provider will perform some tasks such as data enrichment. +Less work for participant + Less prone to error - No audit log for participant - Could be expensive. - Participant is still liable for errors Smaller traders that already execute most of their trades outside of their own environment. Direct Sending the data directly to a repository. RRM and/or a reporting service. + More control + Lower running cost - Could require a large project to set up - Requires in house expertise Medium and larger participants It is also possible to use a combination of these methods. For example, exchange traded deals could be sent by an exchange, and OTC ones via another route.
  22. 22. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 22 Required Solution Activities While this document is not intended to be a comprehensive guide to building a reporting solution, here we identify some key tasks that the majority of participants will need to undertake to have a working solution: Data sourcing and gap analysis Before data can be provided to any destination, it must be sourced from somewhere, be it the E/CTRM(s), trading platform or spreadsheet. It is important to perform a data gap analysis as early as possible to ensure that you have all of the required data from each product type traded. This will involve going through each product type traded, and for each field required (under EMIR or REMIT) ensuring that you know here it can be found. It is not sufficient to simply map to the source field in an E/CTRM, It is also necessary to ensure that the business process in place updates this field. Data mapping and capture There must be a mechanism in place that can rapidly identify all qualifying trades (new, modified, voided etc.), extract the required data items for reporting purposes from possibly multiple systems, and format the data appropriately for transmission to the trade repositories. Furthermore, the data must be validated for missing items, correct formats and codes, and corrections must be made manually or automatically prior to transmission. Whatever systems are in use to capture and process trades including vendor provided, home grown or even spreadsheet-based solutions, they must contain all of the required data items that are to be reported. Furthermore, there must be processes in place to ensure the capture these data items for reporting purposes. Configuration choice and connection mechanism It will be necessary to select the “shape” of configuration choice. It is possible to select several configurations; for example, a large participant could report most OTC and physical trades directly, but chose to use the exchange’s facilities to report ETD, and to upload some rarely traded physical deals manually. If not outsourcing completely and building an internal solution, it will also be necessary to select a connection mechanism. This could involve either building one internally, or purchasing reporting software that has adapters built in. The incumbent E/CTRM system may also have built in adapters to one or more destinations. Data enrichment The various reporting destinations require entities and product to use standard identifiers, such as LEIs, EICs, UPIs, and ISINs etc. There are several entity records for most deal types, and each requires different product information. In addition, some other information, such as “Counterparty status” flags are required. As a result, each trade must be “enriched” with appropriate standard data. The difficulty of this task varies by number of trades, trade types and source system. Reporting software will usually offer a solution to the issue, which will be particularly useful to those with multiple E/CTRMs. In addition, many of the outsourced services offer a partial solution. Pre trade data REMIT requires that pre trade information such as order information be forwarded to ACER. The arrangements for this forwarding are not yet clear. However, it is likely that execution venues will provide facilities (at a cost) for delivery of such data. Participants should monitor market developments to see how this will be handled. We will also be covering it in a later report.
  23. 23. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 23 Issues being encountered This section outlines some issues being encountered in the market by those implementing trade reporting solutions. Updates will be issued regularly. LEIs (Legal Entity Identifiers) An LEI is a globally unique identifier for counterparty. The LEI initiative also arose from G20 desires after the banking crisis, to create a globally uniform mechanism to identify an entity in a transaction. This eventually led to the Financial Stability Board (FSB) issuing a paper and outline for how such a database could be constructed and governed. The global database is not yet ready, but a “pre LEI” database is being formed, and others already exists in the absence of a final global version. EMIR will require the use of LEIs, or pre LEIs upon go live, although they have not yet been defined for all entities. Market participants will need to: - Add facilities in place to map their existing entity Ids to LEIs - Add facilities so that it is possible to store an LEI for each entity going forward. It is interesting to note that there was a distinct lack of LEI registrations on Feb 12th, with a surge of registrations occurring later. Clearly the LEI rollout is not yet complete. The UTI (Unique Trade Identifier) Trades sent to EMIR repositories need to contain a 52 character UTI. Under EMIR, both sides of the trade must send in a deal with the same UTI. The generation of this ID and the workflow around are leading to a great deal of uncertainty at the time of writing. In particular: Generation of the UTI – There is no mandatory mechanism for the generation of the UTI, which has been left by ESMA to “the industry”. An ISDA working group is currently attempting to provide for a recommended solution although this is not yet final or accepted by all in industry. The commonly accepted approach depends on whether the trade is executed on a platform or not. If it is, then the platform should generate the ID for both parties. For bilateral trades, the consensus is that the seller should generate the ID and provide it to the buyer. However until this is agreed, the resolution is as yet unknown. Workflow around the UTI – However the UTI is generated, it needs to somehow make it into one or both party’s ETRM systems, and be sent to a repository. If the trade is executed on a trading platform, it will be necessary to extend the interface between the platform and the ETRM to capture the UTI before the trade is sent to ESMA. For bilateral trades, the capture of the ID is harder: the generating party must find a way of providing it to the other side, and this will need to be electronic since manual entry of a 52 character code is not an option. It is worth noting the triOptima, EFETNet and Trayport all have useful UTI generation tools. The obvious place for the code to come in is on the trade confirmation. However, that may not arrive until after the trade must be reported to ESMA. In an update to the Questions and Answers on EMIR, that was issued by ESMA the night before go live, some new guidance was given on the format of UTIs. However this format is also not mandatory. The solution to the issue will need to evolve over the next months.
  24. 24. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 24 Which rules apply to a trade? It is important to have a granular and flexible mechanism to ensure that trades get “routed” to the correct place under the right rules. Firstly, the definition of a derivative under EMIR is not always straightforward and subject to change. The rules as outlined in the “threshold calculation” section require: - A “hedge marker” to be placed on all trades in the source system. In some cases, a rule could be used to derive this, for example if all hedges are in specific portfolios. In other cases, they will need to be marked manually. - It is import to have mechanism in place that can deduce whether a trade has been executed on an MTF. The list of MTFs keeps changing, and this must be factored into the solution Furthermore for some trades executed via brokers it may be difficult to determine the place of execution in the first place. Expect the recent FCA ruling to be modified as well. Similarly, with REMIT, it will be necessary to have a flexible mechanism in place in order to determine which trades to cover. Changing requirements As market participants get closer to go live and further into their projects, more detailed issues are emerging. At the same time, messages from regulators repositories and others give rise to changes and intricacies. It is important to keep a close eye on developments. This can be accomplished over various forums including the website www.enegrytradingregulation.com and via updates to this report through time. Advertisement
  25. 25. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 25 Risk Management EMIR specifies five different measures that must be adopted by market participants: Timely confirmations – All trades must be confirmed (matched) within a certain timeframe Portfolio reconciliation- Uncleared bilateral trades must be reconciled between each set of parties at pre-defined intervals Dispute resolution – Dispute resolution procedures to be put in place for trades in dispute for more than 5 days Portfolio Compression – Certain parties must perform mandatory compression on OTC deals Daily mark to market/model – Trades to be marked to market or model by certain parties. The requirement and timeline can be summarised by this chart: Rule Summary FC NFC+ NFC- Timing Timely Confirmation Bilateral Trades to be confirmed (and matched) within the given timetable. T+1 T+2 Requirement for T+7/5 came in on 15th March 2013. Window narrows every few months until August 2014 when the timings shown here will be required. Portfolio Reconciliation Uncleared trades to be matched periodically between counterparties. Daily for portfolios greater than 500 trades. Weekly for portfolios with between 51 and 499 trades. Quarterly otherwise. Quarterly for portfolios of more than 100 trades. Annually otherwise. Starts on15th September 2013. Dispute Resolution All to have processes in place to identify, track and monitor disputes. Formal procedure if more than 5 days. Report all disputes over 15 days and 15M EUR Procedures must be in place. Starts on15th September 2013. Portfolio Compression OTC trades to be “compressed” periodically. Twice a year for portfolios with more than 500 trades. Starts on15th September 2013. Daily mark to market/model All trades to be either marked to market or model on a daily basis. All trades that are sufficiently liquid to be marked to market daily and the values sent as part of trade reporting. Otherwise they must be marked to model and values sent. Not required.
  26. 26. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 26 Timely confirmation The timely confirmation requirement of EMIR is intended to reduce risk and encourage a move to electronic confirmations. The confirmation deadline refers to the time the trade is confirmed as matched, rather than when it is sent. Portfolio Reconciliation and Dispute Resolution EMIR requires that counterparties reconcile their portfolios of uncleared trades from 15th September 2013 onwards, as follows: FC and NFC+: More than 500 trades: Daily Between 50 and 499 trades: Weekly 49 or less: Quarterly NFC-: More than 100 trades: Quarterly Less than 100 trades: Annually. Where an NFC- is the counterparty of an NFC+ or FC, the NFC- timings apply. Generally, for those with many reconciliations to perform, there is a good case for automation, if it does not already exist. There is clearly far less work to perform for an NFC-, which reduces that case and will give rise to the reconciliations being performed manually. However, NFC-‘s are advised to calculate exactly how long this will take. A medium sized utility with 20 counterparties with over 100 trades will still need to do 20 of these per quarter, i.e. one every 3 working days, and also have the overhead of the annual reconciliations, which may be numerous. Consideration should therefore be given to at least a “semi-automatic” solution. The reconciliation process In order to reconcile trades, the two parties must exchange the position each thinks it has with the other. In order to do this each party must provide data to the other so that it will be “matched”. (Usually via a file). The file will contain a pre agreed set of fields, known as the “key terms” that can be used to identify a specific trade. In addition, fields such as price and notional and sometimes mark to market will be sent. The parties then take each file and compare them using the key terms. Those where the key terms and positions are the same are declared a “match”. If there is no match or a large difference in views are marked in dispute. In reality, not all fields will always match, and so the parties declare a “tolerance” for the key terms. Those that are in dispute then are checked and if that cannot be resolved, the dispute resolution procedure commences. There are various ways in which this may happen: Typical modes of operation In general, there are three usual modes of operation: Bilateral – where counterparties exchange files (either one or both ways). Third Party Service provider – Where a third party is involved in the reconciliation, to organise it as a central service. Agent – Where another party performs the reconciliation on the counterparty’s behalf.
  27. 27. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 27 Bilateral reconciliation Before reconciliation starts, counterparties will need to establish procedures/systems to monitor how often they must reconcile with each entity. This may vary over time. Once established, a reconciliation schedule needs to be agreed with the other party (except for daily reconciliation). On the day of the reconciliation, the parties exchange data files. In some cases, only one party sends the file for the other to check. The fields contain the data in the key terms as well as position data. They then run matching processes, using the key terms and tolerances. If there are “breaks”, the parties communicate and fix them, or if necessary initiate the dispute resolution procedure. The matching itself can be performed by specialist software, or using a spreadsheet. Spreadsheets can be complex in this area, although the introduction of the UTI will make this task easier. The benefit of the bilateral approach is that it is simple to use, especially for those with a small number of reconciliations to perform The drawback is that any counterparty with more than a handful of reconciliations to perform will need to send a large number of files to different counterparties on the correct dates. This can become logistically complex and lead to operational risk, and the wrong fields being sent to the wrong places, risking a breach of confidentiality. Third Party Service Provider An alternative of bilateral reconciliation is to use a third party to assist in the process. –Using this method a third party service such as the triResolve service provided by TriOptima is used centrally to organise reconciliation. They do not however, perform the reconciliation from a legal perspective. They simply organise the process and make it easier than a bilateral reconciliation. When using the service provider model, each subscriber sends a file on a regular basis to the service provider, containing data regarding other subscribers. The service then calculates how often reconciliation is necessary and performs the appropriate scheduling. It then performs the matches and informs the subscribers of any disputes, after following a prescribed process. There are several benefits to this approach: Firstly, only one set of data needs to be sent for all of the subscribing counterparties. This greatly reduces operational risk and the logistical overhead. The second benefit is that the service will provide scheduling services on behalf of the client. This removes the scheduling overhead of the bilateral approach. A service provider will be able to optimise the schedule whilst taking into consideration all of the subscribers simultaneously. Agent Using this paradigm a third party performs the reconciliation on the participant’s behalf. The entire process is outsourced to another party, who perform the reconciliation on their behalf. They will be given the portfolio to reconcile and advise of disputes if they arise and cannot be resolved by the agent themselves. Contractual Changes required for Portfolio Reconciliation and dispute resolution Market participants are required to amend their ISDA and other contracts in order to accommodate these changes, the contract should encompass the new protocols that permit information sharing for the appropriate key terms in order to reconcile, as well as requiring the reconciliation to take place. See the ISDA website for more details.
  28. 28. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 28 Portfolio Compression Portfolio Compression is the process of reducing the number of trades in a portfolio whilst maintaining a risk equivalent position. Reducing “unnecessary” trades with a counterparty reduces credit risk and settlement risk. EMIR mandates compression for FCs and NFC’s every six months for counterparty portfolios with more than 500 trades. EMIR also “encourages” compression wherever possible. Compression is not always easy or desired by all in an organisation, although it is desired by the credit department and has many benefits once in place in terms of risk management. Compression can be performed either bilaterally or multilaterally. Bilateral Compression When one counterparty attempts compression directly with another, there are several steps: 1- Identify counterparties – It is necessary firstly to identify which counterparties are being compressed with and when to schedule them for. 2- Identify areas for compression – An analysis of the portfolio must be carried out in order to determine which trades may be compressed, if any. 3- Agreement of compression – the two entities must then agree the set of trades 4- Execute compression – execution of a compression involves terminating the deals being compressed, and replacing them with new ones. 5- Mark trades- The new trades must be marked as “resulting from compression” in EMIR trade reporting. The ETRM system will need to record this as a reason for the trade. Multilateral Compression Compression involving several parties can be a great deal more effective than bilateral compression. Multilateral compression involves viewing the trades between all of the counterparties in a group, and then reducing them down as much as possible using a combination of trades and closures. The more parties involved in a compression, the more benefit it will have. TriOptima‘s triReduce service offers such a service, both within the energy industry and within banking. Multilateral compression involves the following steps; 1- Set calendar – multilateral compressions take place periodically (typically quarterly depending on market characteristics). 2- Send in trade portfolio – each party sends in candidate trades with the other entities in the group to the service. Nominate trades – each party agrees to the compressions from the suggestion list 3- Dress rehearsal – on a specific day, the compression is “simulated” by all parties 4- Execution – On a nominated day, all of the agreed trades are closed out and new ones created. Service suggests trades – the service will suggest which trades can be compressed, which trades will need to be closed out and which new ones created A typical cycle lasts two weeks, with trade submission and matching in the first week, and dress rehearsal and live execution in the second week. As with bilateral compression, all trades resulting from a compression must be marked and reported.
  29. 29. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 29 Is it worth compressing if it is not mandatory? As outlined above there are many benefits to compression, in particular credit risk reduction. One other benefit that applies in particular to non-financial counterparties, is the reduction in total Gross Notional Value. By compressing enough trades, an NFC- may be taking them further away from the threshold, which could be considered a great advantage. Other benefits include: o Capital cost: With the Basel III leverage ratios it is quite beneficial to reduce gross notional o Balance sheet: Compression also reduces gross mark-to-market, which under IFRS accounting will decrease your balance sheet o Operational costs and risks: Compression leads to fewer trades that needs to be processed through its lifecycle, i.e. fewer lifecycle events like scheduling, settlements, payments, etc. to process, where each step has a cost and risk associated Daily mark to market/model All FCs and NFC+s are required to mark all trades to market daily. If this is not possible then trades must be marked to an approved model. It is also necessary to report these valuations daily, as part of trade reporting, six months after the initial reporting date.
  30. 30. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 30 European Regulatory Solutions Directory We have made an effort to identify a variety of possible solutions for the European Regulatory environment and assembled this directory. This is most certainly not the total picture and we will add to it through time to try to keep it up to date. Please note that the product descriptions are often lightly edited versions of the vendor’s web content associated with the product and we are not responsible for any errors in this content. Please also see the CTRMCenter software directory at http://www.ctrmcenter.com. Types of service and software There are a variety of services and software that can be considered when implementing trade- reporting solutions: Trade Repositories – Trade Repositories that have applied under EMIR. Reporting Services – Third party services to which data can be reported and sent on to a TR or RRM. In most cases these will be acting as RRMs Specialist Reporting and aggregation software – Software specifically designed to take in data from one or more sources including ETRMs and reference data systems and send it to one or more Trade Repositories and /or reporting services ETRM offerings – Adapters from ETRM vendors that link their systems (only) to one or more destinations. Exchange Offerings – Exchanges offering to report information about deals executed there. Trade Repositories A number of organizations applied to ESMA for registration as Trade Repositories including; the CME Group, the London Stock Exchange, Intercontinental Exchange (ICE) Trade Vault, REGIS-TR, LSE Unavista The Independent Data Repository, KDPW-TR and, The Depository Trust and Clearing Corporation (DTCC). Those in bold have so far been approved by ESMA. It is interesting to note the provenance of several of these applicants as some already act as Swap Data Repositories in the USA and others as approved reporting mechanisms under MiFID. All of these entities plainly have some degree of experience in collecting and storing trade data. In the USA, Swap data repositories (“SDRs”) were new entities created by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) in order to provide a central facility for swap data reporting and recordkeeping. Some seven entities applied to become SDRs but two applications were later withdrawn and a third does not cover commodities as an asset class. The four remaining include BSDR LLC, CME, DTCC and ICE where BSDR LLC is a new entity specifically
  31. 31. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 31 created for the purposes of becoming an SDR. CME, DTCC and ICE are all applying for registration under EMIR too. LSE has some experience as regional trade repositories for MiFID. Only REGIS –TR and the Independent Trade Repository Ltd. have no real prior track record having been specifically set up for EMIR, although with a test system having been live already for several months; REGIS TR is proving to be popular. KDPW-TR is the central securities depository of Poland and has some experience of working with large amounts of trade data as a result. CME Group The CME's Swap Data Repository Service already provides public data on swap transactions and stores confidential trade and position data for regulatory purposes, in accordance with the Dodd- Frank Act. The CFTC approved its repository service as a swap data repository (SDR) for credit default swaps, interest rate swaps, commodities and foreign exchange asset classes. CME Europe's cross-asset trade repository solution is to launch on 1st January 2014 in line with the first reporting requirements, In addition to operating for CME's global clearing and execution facilities, it will accept non-cleared bilateral OTC and exchange trades executed anywhere in the market. The CME Repository Service leverages the CME ClearPort front-end, a gateway to CME reporting and clearing post-trade services. This common point of connectivity offers messaging efficiency and lower maintenance costs. LSE The London Stock Exchange Group also has applied to ESMA for its UnaVista platform to be a trade repository across all asset classes for both exchange traded derivatives and OTC derivatives. UnaVista currently operates as a European Approved Reporting Mechanism (ARM) under the MiFID regime for all asset classes and markets. LSE believes that by becoming a trade repository for all asset classes across all venues, its customers will only need to connect once to meet both their EMIR and MiFID reporting requirements. As a MiFID Approved Reporting Mechanism (ARM), UnaVista already reports c1 billion multi-asset transactions annually to multiple regulators, including over 300 million derivatives on behalf over 600 clients. As a hosted central utility, UnaVista will utilize its inbuilt reconciliation engine to facilitate the ESMA requirement for contract details to be reconciled before reporting to the various different trade repositories ICE ICE has decided to establish ICE Trade Vault Europe Limited (ICE Trade Vault Europe) as a Trade Repository (TR) for the reporting of derivatives trade data to meet requirements of the European Market Infrastructure Regulation (EMIR). It plans to serve the commodities, credit, interest rate and foreign exchange asset classes. In June 2012, ICE Trade Vault, LLC (ICE Trade Vault US) became the first Swap Data Repository (SDR) in the U.S. to receive provisional regulatory approval from the CFTC and the Vault began accepting credit default swaps trade data in October 2012 followed by commodities trade data in February 2013. Since its inception, ICE Trade Vault US has already accepted around fifteen million trades. Since ICE provides direct access to the core energy and commodity market infrastructure, it believes itself to be a qualified trade repository for those markets. Through the ICE trading platform and clearing houses, as well as ICE eConfirm, ICE sees an opportunity to simplify workflows and trade
  32. 32. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 32 data reporting requirements for market participants, helping its customers achieve efficient and cost-effective compliance with evolving regulations. Utilizes ICE eConfirm as the front-end application for counterparties to submit data to ICE Trade Vault, thereby enabling market participants to use their long-established connectivity solutions with fewest modifications possible Distributes real-time trade data to market participants and provides historical data for online viewing and access. Participants will control permissions for regulatory reporting purposes as well Features a high-performance, scalable data warehouse and reporting platform ICE is likely to also act as an RRM. REGIS-TR REGIS-TR is a European trade repository created as a joint venture by Clearstream Banking S.A. (Deutsche Börse Group) and Iberclear (Bolsas y Mercardos Españoles). Its services have been operating live since 2010. Derivatives based on interest rates, foreign exchange, commodities and equities are currently eligible for registration at REGIS-TR, which will enable full compliance with EMIR for all asset classes and listed derivatives before the reporting obligation comes into places. Key characteristics of REGIS-TR are as follows; European provider, fully compliant with EMIR, with a Financial Market Infrastructure (FMI) license Co-owned by two neutral securities services infrastructures, providing services from Luxembourg, holding data exclusively in the EU One-stop-shop for the registration of all types of derivatives on all asset classes Flexible access for all types of counterparties (financial and non-financial entities) Competitive price list allowing full price transparency and predictability. Fee caps for all users Commitment to be a REMIT RRM Flexible trade delivery mechanism spanning simple upload of csv files to a web services based XML sending mechanism. REGIS-TR will enable full compliance with EMIR’s derivatives reporting requirements. However, it also allow customers to meet their obligations for transaction reporting under the Markets in Financial Instruments Directive (MiFID), the Regulation on Energy Market Integrity and Transparency (REMIT) and repo agreements and securities lending reporting under the Capital Requirements Directive (CRD IV). In addition to its statutory trade repository activities, REGIS-TR may also offer its clients extra services such as electronic matching and confirmation services, independent valuation services and exposure management. REGIS-TR and TriOptima have also recently announced that they will provide portfolio reconciliation of REGIS-TR’s trade repository data with data in TriOptima’s triResolve reconciliation service for OTC derivatives as requested by their clients.
  33. 33. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 33 The Independent Trade Repository CapitalTrack, a vendor of a data transfer database and network, Capital Market Daily Portal, a data network, technology and services vendor, and Fincore, a software vendor, have established a new company, Trade Repository, and hope to win ESMA approval for its Independent Trade Repository product. The Independent Trade Repository will allow users to submit the details of their trades on spreadsheets to its online database. The Independent Trade Repository believes that it will be particularly attractive to market participants because it is not affiliated to a clearinghouse and because the companies operating it have an expertise in data management. DTCC DTCC’s Global Trade Repository (GTR) Service provides full coverage of all cleared and uncleared OTC derivatives products within each major asset class. Trade submissions will be supported for 100% of products traded in each asset class regardless of whether trade is electronically processed or bespoke – paper confirmed. A customer of a Repository may selectively elect to enable reporting for one or more jurisdiction/regulation that is supported by that Repository. For example, a member of the DDRL legal entity may elect to report to any combination of ODRF, HKMA, CSA, and ESMA. The above TR entities can also be registered as foreign TR in other jurisdictions, e.g. Canada and Australia. The GTR service supports a multitude of data submissions including real-time price reporting, transaction details, confirmation records, and valuation data. The GTR service provides open access to third-party providers to promote efficient reporting processes – this includes: Electronic Execution Platforms Confirmation Providers Clearing Houses (CCPs) Inter-dealer brokers Custodians Any other middleware providers The GTR is brought to the energy industry by EFETNet who have partnered with DTCC in the US and will offering forwarding of trades under EMIR to the repository via the eRR service.
  34. 34. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 34 KDPW-TR On 2 November, the Central Securities Depository of Poland (KDPW) launched the trade repository service (KDPW_TR) in response to Regulation No. 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties and trade repositories (“EMIR”). According to Article 48.5a of the Act on Trading in Financial Instruments of 29 July 2005 as amended by adding provisions concerning novation, the Central Securities Depository of Poland (KDPW) may – under the rules set out in separate rules – collect and store information concerning trade in financial instruments and information concerning such instruments. The detailed operating rules of KDPW_TR are set out in the Trade Repository Rules.
  35. 35. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 35 Reporting Services NASDAQ OMV NASDAQ OMX already provides a service for Nordic Market Participants for MiFID trade reporting (TRS) to local Financial Supervisory Authorities (FSA) and will extend this reporting service to cover EMIR derivative reporting to Trade Repositories. It offers its members reporting services regarding: Establishing connectivity with relevant Trade Repositories Reporting of derivatives contracts traded and cleared on NASDAQ OMX’s markets Reporting of OTC derivatives transactions that are not traded or cleared by NASDAQ OMX Ability for members to append required data to derivatives transactions for reporting Daily updates to the Trade Repository of collateral and mark-to-market valuations Reporting feedback of submitted reports NASDAQ OMX further aims to extend its service to include reporting obligations under REMIT for the energy market. It provides the option of full service reporting of all required data and a complimentary reporting service where NASDAQ OMX and the Customer jointly complete the reports. For derivatives cleared with NASDAQ OMX where the Market Participant keeps position-segregated accounts per beneficial owner, NASDAQ OMX can complete the Trade Repository report with all required data without the need for interaction from the Customer. For Customers with a setup where NASDAQ OMX does not have access to all required data or where the Customer selects to submit its own reports to a Trade Repository but need NASDAQ OMX to complement their reports with some data, it will offer a partial reporting service according to the alternatives described below: For Customers that connects to a Trade Repository themselves for reporting, NASDAQ OMX will duplicate the missing data at the Trade Repository to the report created by the Customer. Alternatively, the Customer can complete partial reports created by NASDAQ OMX and submit the reports to the Trade Repository through NASDAQ OMX. This option does not require direct connectivity to a Trade Repository for the Customer. OTC derivatives transactions that are not traded or cleared by NASDAQ OMX may also be submitted via the service interface. This option, also, does not require direct connectivity to a Trade Repository for the Customer. The service is provided with a flexible interface where the Customer can select to interact with the service via a provided application or by uploading fixed formatted files. The Trade Repository application is a desktop application that enables the Customer to perform the following activities: View status of submitted reports View status of individual reported transactions Search for historical reports
  36. 36. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 36 Review and confirm NASDAQ OMX generated reports Complement partial NASDAQ OMX generated reports with additional data before submission Create new transactions for reporting Export data to external systems Vendor – Nasdaq OM http://www.nasdaqomx.com/europeanclearing/traderepositoryservices/ EFETnet eRR EFETnet’s electronic Regulatory Reporting (eRR), is an industry wide solution to an industry wide problem; implementation of regulatory reporting requirements is having a significant impact on the wholesale European energy market. Operational processess and systems are under pressure because of the changing regulation and investments in IT are inevitable to comply with all regulatory reporting obligations. EFETnet developed eRR, a single standardized interface for regulatory reporting, delivering reporting compliance for REMIT, EMIR, MIFID, CRD IV etc. eRR operates through a single open industry standard interface providing connectivity to the different regulatory repositories. eRR will be offered as an add on to EFETNet ‘s confirmation matching service, which is already used widely in the industry. Trade information will be sent using the same protocol and format and for confirmation matching. Trade information will only need to be sent once for both confirmation and regulatory reporting. EFETNet uses the CpML format to represent trades. In order to encourage that use of this format as a standard, its management is now being given to an independent body run by EFET and the CIO Council. This will permit other vendors to use CpML in order to encourage interoperability. The initiative to carry this out has already begun. Vendor – EFETnet http://www.efetnet.org TrayPort Complete Trayport Complete is designed to reduce the operational costs and delays associated with trading energy commodities. The Complete suite of real-time solutions will provide market participants with transparency and control over their post-trade activity. With Complete, users will be able to accurately manage and monitor their post-trade workflows across the 160+ markets accessible through Trayport's platform immediately following the trade. Complete will be seamlessly integrated with existing Trayport products and will enable users to:
  37. 37. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 37 Clear – Users can see the status of trades in real-time across all clearing houses and counterparties on the Trayport network through one screen. Complete Clear is live and available for CME ClearPort, LCH, MEFF, NOS and SGX. Connectivity to European Commodity Clearing AG (ECC) and OMIClear will be announced in the coming weeks Confirm – Users will be able to confirm standardized terms of a trade immediately post execution with up to 400 counterparties and 17 brokers on the Trayport network. Complete Confirm will enable users to define their own confirmation processes and workflows to meet their internal requirements. This will improve efficiency, optimize workflows and reduce operational risk and the processing costs associated with energy trading. Report – Users will be able to report as close to real time as they choose to European regulatory authorities and trade repositories. Complete Report will be designed to satisfy REMIT and EMIR regulatory reporting obligations at the point of execution. Further reporting obligations and jurisdictions will be added in the future. Control – With Complete Control, users will be able to manage post-trade execution with transparency and control. The real-time monitoring application will allow all counterparties to the trade to track the progress of their trade and immediately identify and resolve any questionable trades at the point of execution, significantly reducing operating risk and cost. Vendor – Trayport http://www.trayport.com Specialist Reporting and aggregation software BroadPeak - K3 BroadPeak is an integration/ETL software firm. Its flagship product, K3, is a low latency, fully audited integration/ETL platform for simplifying trading integration. Used in production at banks, trading merchants and hedge funds, K3’s low latency integrations with Exchanges, Trade Repositories, Price Sources and ensure audited, transparent and correct delivery of data payloads. K3 has current off the shelf integrations for both Dodd-Frank and EMIR compliance. Purpose built to meet FC, NFC+ and NFC- reporting demands, K3’s off the shelf connections include, ICE Trade Vault, CME, DTCC and Regis-TR. K3 also has existing connections to most ETRM systems including, OpenLink, Triplepoint, Amphora, Allegro, Eka, Sungard and Brady. For ad-hoc reporting, BroadPeak also offers cloud based drop copy service that allows users to drop an Excel sheet of trades into a local folder that is picked up by K3 for routing and transformation to the TR of choice. Vendor – BroadPeak Inc www.broadpeakpartners.com info@broadpeakpartners.com
  38. 38. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 38 EMIR-ate.com emir-ate.com is a service provided by Treamo Business Consulting GmbH. and is a cloud-based SaaS- solution that helps corporates comply with the reporting requirements of EMIR. It interacts with existing systems and tools (TMS, spreadsheets, trading platform) as well as with the Trade Repository. It is a service that ensures EMIR compliance at the press of a button. The trades will be reported via XML files. At the moment, the Trade Repository requires approx. five minutes for the return message that either confirms the correctness of data or contains a list of errors. EMIRate will convert these status messages in an understandable format and will present the result of the return message in the list of trades, where users can, for example, filter all those transactions, which have been sent but not yet acknowledged. The same also applies to messages regarding the reconciliation status. Vendor – Treamo Business Consulting GmbH http://www.emir-ate.com DeltaconX/Tradelogic DeltaconX Captures the compliance data held in your trading, financial, and logistical systems, transforms them into the correct message structures, and routes them to the appropriate regulatory reporting destination such as Trade Repositories, CCPs, RRMs, ARMs, and ACER. Response and status messages are captured as part of the submission process and relayed back to the source systems. A full audit trail of data processing and transfers is maintained. There is no need to upgrade your trading system as all the required and missing data can be added directly in DeltaconX. DeltaConx is being offered to the market together with TradeLogic as implementation partners. Vendor: CH Consult GmbH http://www.deltaconx.com Finalyse FINALYSE offers an automated solution for the new European Market Infrastructure Regulation (EMIR). This solution can be easily implemented on site or externalized towards Finalyse (Third Party). The goal of this solution is to allow customers to be EMIR compliant with a minimum of investment costs and to benefit from our expertise in terms of European regulation and implementation solutions. The main advantages of the solution are:
  39. 39. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 39 EMIR Compliant Data Model Our EMIR data model is compliant with the new regulatory standards of the European Securities and Markets Authority (ESMA) and is built according to the most modern and advanced data model design techniques (full auditable, security and normalization). Furthermore, it will store a complete history of all transactions. Automated Data Quality Checks Our EMIR data model is verifying the data for completeness and is transforming the client’s specific naming conventions into the EMIR required taxonomy. Specific data quality errors are monitored and reported for improvement. Automated Reporting to Trade Repository Our solution is an automated process flow for the reporting of modifications, valuations and trade terminations towards one of the major trade repository systems. Furthermore, the process reports information coming back from the TR (e.g. uncommitted trade reports). Easy Implementation or Full Outsourcing Finalyse’s solution for EMIR consists of a data model concept and process flow which can be easily implemented on site. The remaining workload is to build a bridge between our ready- to-use solution and the client’s internal data system(s). Furthermore, customers can delegate the reporting as well towards Finalyse, which will act as Third Party. Vendor – Finalyse http://www.finalyse.com Seven2one Steria Mummert Consulting AG and Seven2one Informations systeme GmbH offer companies subject to reporting requirements a mature, holistic solution for secure, transparent and cost efficient reporting that is fully compliant with the EMIR and REMIT regulations. The solution includes; EMIR/REMIT compliant data model Automated collection of data from upstream systems and reporting: any data format possible, no adaptation required Stable, automated and auditable reporting processes Integrated data quality checks ensure highest data quality Simple and transparent monitoring of data, processes and reports Easy implementation in your own company, full outsourcing or SaaS Can be expanded to comply with future reporting requirements (e.g. MiFID, Bafin) Secure investment with added value and full cost control (fixed price offer) Wide variety of functions (portfolio comparison, risk cockpit, compliance relevant evaluations, e.g. market manipulation, market abuse) High professional utility, e.g. mapping of electricity products with complex profiles, mapping of orders for REMIT, serves all asset classes (FX, IR, commodities) Immediate implementation, project can be started immediately Full control over reportable data, data streams and generated reports
  40. 40. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 40 Reporting with added value: expandable without programming to comply with further reporting obligations (e.g. MiFID, BAfin) even up to the production of an internal reporting tool for trading and risk management Tried and tested standard software solution offers a high degree of reliability Rapid integration of new reporting obligations through modular updates Strong partners offer extensive experience with both the technology and sector A broad range of services provide optimum support - from professional consulting on the regulatory framework to the implementation of an automated solution to operation of the software Vendor – Seven2One http://www.seven2one.de Impendium Elements Impendium Systems Elements is a Private Cloud Platform that enables you to be compliant with multiple regulations throughout the world using a single solution. Unlike traditional approaches and vendors we incorporate the technical elements of common global regulations onto the Platform enabling you to be compliant sooner. Report to regulators, central banks or even internal departments using Elements in a timely and cost efficient manner whilst having a complete single view of your regulatory data. Elements is a specifically engineered regulatory platform. Impendium Systems Regulatory Advisory Board – made up of industry and regulatory experts – continuously studies the global regulatory roadmap and ensures that key regulatory components are incorporated directly into the Platform. Elements services many current financial regulations including as Dodd-Frank, EMIR, REMIT and MiFID and work is underway on future regulations such as MiFID II and MAD II. Vendor – Imperium Systems http://www.impendiumsystems.com Lombard Risk REFORM The Lombard Risk REFORM platform is a highly configurable solution designed to help firms manage predominantly trade-related processes – such as pre-/post-trade processing and regulatory transaction reporting. Right now firms are using REFORM to meet the global regulatory transaction reporting requirements. Lombard Risk REFORM is designed for real-time regulatory transaction reporting, will
  41. 41. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 41 interface seamlessly with an organization’s banking (or other) systems, and is ideally suited for EMIR (as well as Dodd-Frank, MiFID and REMIT) that are being introduced to monitor and regulate the OTC derivatives market. Vendor – Lombard Risk http://www.lombardrisk.com OpenLink – RegCube The EMIR and REMIT business intelligence solution is an extension of OpenLink's CubeIntelligence portfolio. The new online analytical processing (OLAP) based cube offering provides financial institutions and organizations in other verticals, particularly energy firms, participating in energy and financial trading a speedy and cost-effective way to comply with the new reporting and reconciliation requirements. The CubeIntelligence team has developed the OpenLink REG Cube to ensure clients continue to have access to the market while remaining compliant with the new regulations set to come into force this year. The OpenLink RegCube offers firms the ability to: Generate the regulatory reports that firms must provide daily to trade repositories and registered reporting mechanisms Send the data to EMIR TRs and REMIT RRMs Calculate and record the gross notional values in line with EMIR View the EMIR and REMIT values for the entire firm and also drill down, by all categories into trade level detail if required Easy integration of multiple source systems (whether produced by Openlink or not) using a simple interface which offers trade enrichment with reference date and other complex rule based transformations Specify which trades, books or products are in scope of the regulations so users can filter on these criteria to calculate the EMIR and REMIT values for the in-scope trades only Enrich and transform data before sending to the Repository using a complex transformation engine Perform bilateral portfolio reconciliation using the data already in the cube combined with file production and matching facilities The cube is integrated with other cubes such as the Risk Cube. It can be used as the basis of a cross company business intelligence solution. Openlink also supply an “accelerator” from Endur and IRM so that those systems can be connected to the cube with a short implementation time. Vendor - OpenLink Financial http://www.olf.com
  42. 42. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 42 Energeya – XDM Compliance Energeya’s XDM© COMPLIANCE allows users to manage manage regulations as a Business Process with a complete environment of tools and processes for full requirements management versus local and international Compliance Regulators. The solution is multi-regulation, rules-based, data-independent, workflow-based and provides batch support. It is part of XDM© Suite for commodities management, and is available both stand alone or together with other Energeya’s commodities and process management modules. As a standalone solution, XDM© COMPLIANCE can address the Compliance requirements also for customers who already have other ETRMs or Contract Management systems: in this case, XDM© COMPLIANCE takes advantage from the full modularity of the XDM© platform, providing the Customer with a lightweight version of the XDM© system but with the whole set of infrastructure core modules. Vendor: Energeya http://www.energeya.com e·Opt PriceHub e·Comply PriceHub e·Comply has been developed by e·Opt Solutions, a Germany based provider of solutions in the Energy Trading space. It is a comprehensive tool for Regulatory Reporting under EMIR and REMIT and is targeted towards the obligations of most medium to small sized energy companies in Europe. It is a viable tool for this market and though currently built for EMIR and REMIT, it can be easily extended to serve future Regulatory challenges. e·Comply has an intuitive and transparent workflow. It offers extensive Reporting and interfacing possibilities as well as an open data model for upstream source systems, thereby making bespoke interfacing to ETRM or other systems achievable with limited effort. e·Comply already has a downstream interface for REGIS-TR and as other Repositories and RRMs expose their interfaces, e·Opt plans to update its interfacing as well. Two key differentiators of e·Comply have are firstly its ability to seamlessly report Orders to Trade under REMIT, and secondly its Third Party Reporting module. The former uses online interfacing to Trayport and other platforms to gather orders. The Third Party Reporting module allows companies to offer Reporting Services to smaller clients with limited resources and trading operations. With Regulators expected to be increasingly intrusive, the Trade Annotation function is a useful tool to answer background questions on Trades and Orders. e·Comply has been built as a comprehensive Compliance tool for organizations, rather than being limited to EMIR and REMIT. It is deployed as an inward as well as outward looking tool, helping Compliance Managers to satisfy internal as well as external demands. e·Comply is currently live at Syneco Trading GmbH, Enovos Luxembourg and SmartestEnergy UK. The team behind e·Opt, led by its CEO, Rajeev Bhatt traces its roots to years of Energy Trading and Risk Management experience. The PriceHub suite with its various modules for Forward Curves, Price Data
  43. 43. European Energy Market Regulations © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2014, All Rights Reserved. 43 Management, Pricing and related areas, have been built using their experience in Trading and Technology. Vendor – e·Opt Solutions http://www.eopt.org Pioneer Solutions Compliance Tracker Pioneer Solutions' ComplianceTracker provides enterprise-wide compliance tracking, performance monitoring and reporting for corporate, regulatory, environmental and other compliance requirements. ComplianceTracker supports the following:  Compliance requirements administration  Performing activities and monitoring  Approving activities and monitoring  Triggers and exception management  Compliance management  Reporting Vendor – Pioneer Solutions http://www.pioneersolutionsglobal.com Calvus Solutions Golden Trade Repository Many organisations use the regulatory reporting services offered by the exchange or banks with which they trade. However, they remain responsible for providing evidence that all their transactions have been properly reported. CalvusControl™ provides this evidence. We aggregate all the information from each of your banks and exchanges, together with any directly reported transactions, into a single consistent view that provides the compliance you require. Vendor – Calvus Solutions http://www.calvussolutions.com

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