GTR MAS Reporting Code of Practice

Transcription

1 GTR MAS Code of Practice REIT Manager/Trustee Setup Model Last Updated: 30 May 2014

2 Structure Topic Page I. Background and Functionality 3 II. Potential Compliance Timelines. 4 III. Submission Scenarios - on REIT Manager IV. Submission Guidelines for REIT Manager V. Submission Scenarios - on Trustee VI. Submission Guidelines for Trustee VII. Regulator Outputs

3 Background and Functionality Background Under MAS regulations all OTC trades must be reported to a trade repository. The reporting obligation for 2014 covers Interest Rate and Credit Derivatives asset classes. DTCC provides a number of simple reporting options for compliance with MAS reporting requirements. DTCC offers a centralized and flexible trade reporting solution for participants looking to meet their reporting obligations under MAS. This document is meant to be a guide for REIT Managers and Trustees, who have the reporting obligation MAS. GTR Functionality Firms can submit and reconcile their trades directly in DTCC s trade repository. This would be considered a direct submission by the REIT Manager/Trustee or the REIT/Trust Firms can also choose to delegate their reporting to their counterparty or a third party, who in turn, will report to DTCC Regardless of the submission method, the party with the MAS reporting obligation and the party of the reportable trade, would need to be onboarded to DDRS (DTCC Repository (Singapore) Pte. Ltd.). Both REIT Manager/Trustee and the REIT/Trust would need to register for a LEI Submissions should be made using standard DTCC trade submission templates This document assumes the MAS reporting obligation falls on the REIT Manager or Trustee 3

4 Potential Compliance Timelines Firms should consult with their internal legal and compliance team to ascertain their own reporting obligation and compliance date. The table below is simply a guideline. # Scenario Booked In Singapore? d in Singapore? Possible Specified Person ( under MAS) Legal Entity/Party of the Investment Manager Requirement (according to MAS Rules) 1 Singapore based REIT Manager with a Singapore based Trust/Trustee REIT Manager / Trustee Trust REIT Manager 1-Jul-14 2 Singapore based REIT Manager with an Offshore Trust No REIT Manager / Trustee (Offshore) Trust REIT Manager 1-Jul-15 3 Singapore based REIT managed by a Singapore based REIT manager REIT Manager / Trustee REIT REIT Manager 1-Jul-14 4 Offshore REIT managed by a Singapore based REIT manager No REIT Manager / Trustee (Offshore) REIT REIT Manager 1-Jul-15 * Each scenario has very specific setup and submission requirements 4

5 Submission Scenarios on REIT Manager Submission can be done directly to the GTR, or can be delegated. Firms would need to communicate with the appropriate parties if they choose to delegate. Who has the reporting obligation? Who is the Legal Party of the trade? Who will submit the trade? Scenario # REIT Manager R1 Counterparty R2 REIT Manager Trust / REIT Third Party R3 Trust / REIT R4 * Each scenario has very specific setup and submission requirements 5

6 Submission Guideline for REIT - R1 LEI Required? Onboard to DDRS? EOM would be sent to: Trust / REIT, if onboarded directly to DDRS REIT Manager If Trust / REIT is onboarded through the REIT Manager, then REIT Manager Trust / REIT * * Either directly or through the REIT Manager (as multi managed) Agent REIT Manager Trust / REIT Trust / REIT Counterparty REIT Manager MAS fields of the inbound submission should contain: LEI of REIT Manager LEI of Trust / REIT LEI of Trust / REIT LEI of Counterparty Agent LEI of REIT Manager 6

7 Submission Guideline for REIT - R2 LEI Required? Onboard to DDRS? EOM would be sent to: Trust / REIT, if onboarded directly to DDRS REIT Manager If Trust / REIT is onboarded through the REIT Manager, then REIT Manager Trust / REIT * * Either directly or through the REIT Manager (as multi managed) Agent Counterparty Trust / REIT Counterparty Trust / REIT REIT Manager MAS fields of the inbound submission should contain: LEI of Counterparty LEI of Trust / REIT LEI of Counterparty LEI of Trust / REIT Agent LEI of REIT Manager 7

8 Submission Guideline for REIT - R3 LEI Required? Onboard to DDRS? EOM would be sent to: Trust / REIT, if onboarded directly to DDRS REIT Manager If Trust / REIT is onboarded through the REIT Manager, then REIT Manager Trust / REIT * * Either directly or through the REIT Manager (as multi managed) Agent Third Party Trust / REIT Trust / REIT Counterparty REIT Manager MAS fields of the inbound submission should contain: DTCC Account of Third Party LEI of Trust / REIT LEI of Trust / REIT LEI of Counterparty Agent LEI of REIT Manager 8

9 Submission Guideline for REIT - R4 LEI Required? Onboard to DDRS? EOM would be sent to: Trust / REIT REIT Manager Trust / REIT Agent Trust / REIT Trust / REIT Trust / REIT Counterparty REIT Manager MAS fields of the inbound submission should contain: LEI of Trust / REIT LEI of Trust / REIT LEI of Trust / REIT LEI of Counterparty Agent LEI of REIT Manager 9

10 Submission Scenarios on REIT Manager Submission can be done directly to the GTR, or can be delegated. Firms would need to communicate with the appropriate parties if they choose to delegate. Who has the reporting obligation? Who is the Legal Party of the trade? Who will submit the trade? Scenario # Trustee T1 Trust / REIT T2 Trustee Trust / REIT Counterparty T3 Third Party T4 * Each scenario has very specific setup and submission requirements 10

11 Submission Guideline for Trustee T1 LEI Required? Onboard to DDRS? Trustee EOM would be sent to: Trust / REIT, if onboarded directly to DDRS If Trust / REIT is onboarded through the Trustee, then Trustee Trust / REIT * * Either directly or through the REIT Manager (as multi managed) Agent Trustee Trust / REIT Trust / REIT Counterparty Trustee MAS fields of the inbound submission should contain: LEI of Trustee LEI of Trust / REIT LEI of Trust / REIT LEI of Counterparty Agent LEI of Trustee 11

12 Submission Guideline for Trustee T2 LEI Required? Onboard to DDRS? EOM would be sent to: Trust / REIT Trustee Trust / REIT Agent Trust / REIT Trust / REIT Trust / REIT Counterparty Trustee MAS fields of the inbound submission should contain: LEI of Trust / LEI LEI of Trust / LEI LEI of Trust / LEI LEI of Counterparty Agent LEI of Trustee 12

13 Submission Guideline for Trustee T3 LEI Required? Onboard to DDRS? Trustee EOM would be sent to: Trust / REIT, if onboarded directly to DDRS If Trust / REIT is onboarded through the Trustee, then Trustee Trust / REIT * * Either directly or through the REIT Manager (as multi managed) Agent Counterparty Trust / REIT Counterparty Trust / REIT Trustee MAS fields of the inbound submission should contain: LEI of Counterparty LEI of Trust / REIT LEI of Counterparty LEI of Trust / REIT Agent LEI of Trustee 13

14 Submission Guideline for Trustee T4 LEI Required? Onboard to DDRS? Trustee EOM would be sent to: Trust / REIT, if onboarded directly to DDRS If Trust / REIT is onboarded through the Trustee, then Trustee Trust / REIT * * Either directly or through the REIT Manager (as multi managed) Agent Third Party Trust / REIT Trust / REIT Counterparty Trustee MAS fields of the inbound submission should contain: DTCC Account (or LEI) of Third Party LEI of Trust / REIT LEI of Trust / REIT LEI of Counterparty Agent LEI of Trustee 14

15 Regulator Outputs 1 A LEI should be used to identify the REIT Manager/Trustee in all the above scenarios 2 If either Agent or are populated, the populated values will be reflected on the Regulator Reports. Specifically the following fields must be reported: Agent Prefix, and; Agent Value or; Prefix, and; Value 3 The in the regular report would refer to the reporting obligation of the position, not the party Eg: If the is indicated as MAS and the is not a MAS reportable entity, then the reporting obligation would be the Agent 15