The REGIS-TR RoundUp

S10:E1 End of Year Special 2023: Industry Challenges, Data Field Problems and Predictions for 2024! Merry Christmas!

December 15, 2023 REGIS-TR Season 10 Episode 1
The REGIS-TR RoundUp
S10:E1 End of Year Special 2023: Industry Challenges, Data Field Problems and Predictions for 2024! Merry Christmas!
Show Notes Transcript Chapter Markers

As the curtain falls on 2023, we're thrilled to bring back Head of Client Services and regular co-host for seasons 1-6, Barbara Ruiz Alonso. She's joined by regular host Andrew Keith Walker, Laura Rodriguez, Nicholas Bruce, and John Kernan for the final show of 2023 and the first of our new, 10th Season.

In the new show format, we go in-depth with EMIR Refit's toughest challenges, look at the growing diversity and complexity of global derivatives and money markets, and also make time to find out what the team are doing for Christmas - as well as our predictions for 2024 and it's many new reporting challenges for EMIR, DORA, MICA, CFTC and more. Plus Andrew faces the AI challenge - can ChatGPT replace him? Don't miss it!

Speaker 2:

Hi, I'm Andrew Keith Walker and this is the number one regulatory reporting podcast in the EU, the UK and around the world. So join us as we go behind the scenes and under the hood to look at the big issues and news stories, companies and personalities who are shaping the world of Rektech, fintech and trade repositories. Welcome to the Registr Roundup and remember, this podcast is brought to you by Registr, which is a six company and features members of the Registr team and special guests offering their personal opinions, not the opinions of Registr as an organisation. There is no representation made as to the accuracy or completeness of information in this podcast, nor should you take it as legal, tax or other professional advice. And welcome back to the Registr Roundup for this, our last show of the year. Yes, it's December already.

Speaker 2:

Where did the year go? Well, if you're a market participant, it probably went in preparations for Amir, no doubt, but for us it's been an amazing year. We're going to have a quick review of that. We're going to look towards the future and, of course, this is not just our last show of the year, but it's the first episode of season 10. Yes, it is episode 92 of the Registr Roundup, season 10. And we are full on for Amir Refit coming in just a few months time. We're going to come to that soon. But it's a very special episode too, because one of the regular studio crew, who has been out on maternity leave for a couple of seasons, is back with us. It is also, I'm delighted to say, the return of the nicest and most efficient person in the entire organization, that is, registr. Obviously not the sixth group I'm sure there are nice people there too but the nicest person at Registr are. Sorry, nick, but you know, let's face it, it was never going to be you. Barbara Ruiz Alonso. She's back, barbara, welcome, thank you, thank you.

Speaker 3:

Thank you, andrew. I can't believe it's season 10 already. I don't remember how many I skipped, but time fly. I still remember the first episode we recorded back during the pandemic, and it seems it looks crazy. I only had one time when we started and I have three now.

Speaker 2:

Indeed, you've been busy, your reporting obligations gone right up and, I have no doubt, your lunchbox harmonization is through the roof, so things are looking challenging. It was wonderful to have you back. Of course, barbara is, of course, still the head of client services and joining Barbara for this very special show we have, in no particular order, but starting with the pride of Spain herself, the incredibly talented and, I might add, having met her in the flesh, very tall Laura Rodriguez. Laura, welcome back.

Speaker 4:

Hi, andrew, thank you very much. Where did the year go, actually, as you said, wow.

Speaker 2:

It's really flown by and I'm sure we'll be hearing more about the institutional side of us. And, as you've guessed, joining us my regular co-host, the man who's appeared in the most shows. Without any doubt, it is the voice of reason himself, the head of business development for Registry Armistice, nicholas Bruce. Nick, welcome back.

Speaker 5:

Good to be back, andrew, fantastic. I think Barbara back as well. I'm pretty sure that she needs to recount. I actually must have at least a VivaSide football team by now.

Speaker 2:

Certainly, barbara is formidable on the pitch, but let's face it, if anyone was suited for it, it's the head of client services, because children, as we know, are the toughest clients. And, of course, also joining us, one man who never has to deal with difficult clients because he makes everything run super smooth. It is, of course, the man who used to put the canary in the wharf. Then he was in Devonshire, but never square, and he now looks after St Mary's Acts none other than the CEO of Registry Armistice in the UK, mr John Kern. And John, welcome back.

Speaker 6:

Thank you, andrew, great to be back, and Barbara, so nice to see you back.

Speaker 2:

It's good. So, barbara, I mean I was going to say actually are you going to be coming over to the UK anytime soon?

Speaker 3:

I hope so. I hope I can come over. I just need to find a good excuse. But if I go, of course you will be, together with Nick, the first one to know.

Speaker 2:

Okay, good, good, yes, do let me know, and John see, if you can pull a few strings, I'm sure, and arrange some kind of UK jaunt for the podcast team. That's your challenge for 2024.

Speaker 6:

Yeah, I can feel a UK climb workshop coming on.

Speaker 2:

Excellent, good, I'm glad. Okay, you heard it here first. That sounds great. Now we've got a cut to the real business of today, because we have a lot to get through. We have pages of script ahead and let's start right in at the deep end. Let's look at 2023, because the year seems to have been an incredibly complicated year for market participants. We've seen interest rate rises, inflation, increased volatility, especially for certain kinds of derivatives transactions energy derivatives and, of course, being one of the big ones that's caused a lot of issues for market participants is huge rise, obviously, in repo transactions. So something for the SFTR teams there. There was collateral scarcity last year. This year there's excess liquidity. The funding and financing markets are going crazy and, of course, all of this lands reporting obligations on our clients. So I want to come to you and say what has been the biggest disruptor, you think, over the last year and, of course, this probably will lead into going into 2024 as well. But what's been the big challenge you've seen this year for market participants?

Speaker 3:

Well, to me it's true that I've been off for a few months and for us, I think, well, it hasn't been, let's say, a quiet year, but for sure it's been quite the next year, because our clients have been reading around and starting to get ready for refit, which is, of course, the big bang for next year and it's not anything. So they have been working on it already and, to be honest, I think it's sometimes the hardest part, it's just to get it started. So we heard many troubles on the entities to put together the teams that they needed to prepare for refit, the specialists on each topic, and that might sound like you know, it's easy just to put together two or three people, but it's not, because everyone is busy on other things. So you know, for me the other topics SFTR or on the UK it was more BAU, things were more stable, more kind of you know about fixing and daily activities. So me getting ready for the big challenge next year with refit has probably been the most difficult thing for most of our clients.

Speaker 6:

Yeah, I mean. The other thing I'd say is, I mean rightly so. We, you know our focus has been predominantly email refit, both in the EU and the UK. But it's even more complex for a number of our clients because of course you've had regulatory reporting rewrites the US MAS, etc. So you know they're not only having to prepare for refit but they're also in various stages of implementation of other regulatory rewrites in other jurisdictions. So it's been a really challenging time for some of our clients.

Speaker 2:

Lara, I want to come to you here because, of course, there is a CFTC rewrite that has to be implemented in January. We know that there's a number of refits around the corner in the EU. I mean, I'm guessing that the regulators have got a sense of the pressure that market participants are under, so do you think they're changing their approach over the course of a year that's been so dramatic in its changes, like 2023?

Speaker 4:

Yeah, actually I wanted to talk to you about those challenges, but from the authority side, because obviously one of the points that we have discussed with them has been this readiness for a mere refit. And although we have discussed with them a lot of policy matters, as DTRs we have been able to identify several inconsistencies in the mapping rules, in the validation rules. We have been also able to share with them the readiness that we see right now on the market and several authorities. They didn't have clear that overview the same way. So now, a few months before the reporting start, they really need to start looking into this readiness. They talk with the different entities and really try to find the way to help them, most generally to the small entities that don't have that same capacity as others to build this solution for a mere refit. So they really need to support them now, give them all the information and try to have a smooth implementation. So on the authority side, yes, there will be a great challenge also on this.

Speaker 6:

Yeah, well, I just had an interesting thought from the authority side, and that is as we draw to the close of the year. We've seen the central bank of Ireland recently issue a fine of I think it was somewhere in the region of I think the end assessment was somewhere in the region of 190,000 euros for non-reporting of about 200,000 derivatives trades between 2018 and 2020. So I thought that was kind of interesting and maybe somehow sets a tone for next year and the expectations on the part of national competent authorities in terms of satisfactory implementation of refit and the improved data quality that the refit should hopefully bring.

Speaker 3:

In that regard, I was also thinking that one of the main challenges is when building refit, making refit good enough, because we have all the lessons learned from the past.

Speaker 3:

We know many entities when they build a mere, it was, you know, done, not going to say patches, but some of them they were just building things on the fly, so they did a big thing at the beginning and then, when they had to include improvements or the changes, they already had a basis that was not flexible enough. So you know, now the entities have the opportunity to build something like good enough from the beginning and that it allows them a lot of flexibility for reporting. Plus, we have all the Dora implementation, all the knowledge we have now about artificial intelligence. You know there are a lot of risks now that entities have to consider and that also adds a big challenge for them towards building a good system, robust, secure. So it's really I wouldn't like to be on the shoes of many of the technical guys, the product guys that have many challenges ahead, many considerations to keep in mind and, you know, as usually short timings and normally low budgets.

Speaker 6:

Yeah, and I think what's also concerning Barbara is, you know there isn't complete readiness. We know, obviously, from the events we've gone, to our own events etc. There's some clients who you know you could consider to be behind the curve and I suppose the concern there is you get to a point where actually they look at anything right. Well, the, you know, the only the only possibility for us to execute this in time is to delegate. And that kind of interesting interestingly goes back to the fine as well, because the fine was levied on an entity, if I understand it, that was delegating their reporting. And then also, you know, with the delegation we've had this discussion before, of course, but you know, post refit, it really ramps up as well the fact that you know you can delegate the reporting. You can't delegate the responsibility. You've got, you know, increased requirements in terms of reconciliation process areas and emissions reporting etc.

Speaker 4:

Very interesting this point, john, because actually one of the topics that we commented with the authorities is also their concerns regarding the responsibility of reporting when there is a delegation. So they have seen that several entities that delegates their reporting they seems to delegate full responsibility on their third parties, and this is not the scope of the regulation. If they are the reporting counterparty, they should have full responsibility of what is reported on their behalf, and so they should have access to the data that these third parties are reporting for them. So the authorities have seen that in several locations this is not the case, and they are looking into this because it's an important point to get into into consideration, not only now but also for what's coming now with the refit.

Speaker 2:

So Nick, you're at the sharp end on this, your business development. You're leading across a number of projects. You're interfacing directly with Plides. There are so many moving parts that they've had to adapt to to get ready for a mere refit, especially if you're a delegated entity and and you know, you're relying on someone else. So you're below the thresholds. You're a non financial counterparty. You have delegated reporting to another entity, one of the other entities that's in scope. There's a lot of complexity here. I mean, you know, tell us what is the view out there. Do people have entities, have a really clear idea of how they're reporting and what their data responsibilities are under a mere To try and break that one down.

Speaker 5:

That's quite a long question. Do they have any idea? I think yes, to a degree they do. Does that change their behaviors? I don't think it has done to this point as well, not in all cases.

Speaker 5:

It's a really hard one, because I think one of the things under a mere reporting when you actually look at the changes that we now see in the refit is what the regulators don't want is they don't want a mere to be one sided reporting. So there is a concern, certainly, that I hear that people are just going to move to delegation and actually not take responsibility for what they're reporting, even though they are absolutely responsible for anything to report, whether it's directly or through a third party. Now the question is there's a lot of companies that I speak to that understand that. They appreciate the fact that certainly under refit, they're going to have to have a robust framework of oversight in place. They're going to have to demonstrate that. I think one of the things that's really going to impact, or starting to impact, is, to this point, there hasn't actually been a lot of action from regulators against companies that haven't been in control of their data and have either misreported or have allowed other institutions to misreport on their behalf. Now we're seeing that change with finding regimes actually being implemented and companies being fined.

Speaker 5:

I think that focus is going to change Now. Some of our bigger clients turn around, who are offering delegated services to their clients, and said no, every single client now has to open up a direct account and they need to actually have oversight and be responsible for doing all the errors and emissions reporting on everything that's being reported on their behalf. That is their duty and their obligation. I think we're actually seeing a change in the direction of travel. It's now always been dictated by other market participants.

Speaker 5:

I think that is changing that perception. I think it's a slow change because ultimately, companies got so much on their plate it's hard enough for them to just get their heads around the regulation. We've seen that because we've seen companies that wanted 18 months leading time to adapt, to refit Still haven't done that. We're now in what We've seen that in the last four months and they're only now really starting to mobilize. I think there is becoming a real last minute realization that companies are going to have to do a lot of work and that's going to lead to other issues around resourcing, et cetera, and experienced resourcing. I think that's a real shortage in the marketplace of that.

Speaker 2:

John, you've applied some product development thinking to this, though. How many registries are there? Because you have got a solution for delegated entities that isn't a massive burden on their back office and will allow them to have better data transparency so they can understand their own role and what is being reported on their behalf.

Speaker 6:

Yeah, absolutely. It's not to be transparent. It's not something we've developed for refit. This is something we've had in place for a number of years. If you delegate your reporting, you can still open a read-only account with Registr. It's a low-cost membership as well. Then you can basically triangulate your view so you can see what the TRs books and records, your own books and records and the entity that you've delegated to Maybe it's your custodian bank or whatever. We have such a solution in place. There are hundreds and hundreds of clients who currently use that. We call it an NRE access non-reporting entity access.

Speaker 2:

Getting into the nitty-gritty a bit for you and just trying to get a handle on the challenges of developing products in this space. It's the details of the transaction block of data that has got the most changes. In it we're talking about there's maybe seven new fields that have been introduced for parties to the derivatives blocks. There's a handful of fields that have been added to the valuation side, but we are talking about the bulk of the changes. I think it's 90-plus new fields that have come in the details of the transaction block. One of the key parts here, of course, in terms of reporting, is the introduction of event types and action types. These have changed. They've been rationalized, some have been retired, some have brought over. Barbara, are you finding that one of the issues clients have is they're not 100% sure exactly how to apply event types and action types in the new reporting regime? They still want to use previous systems. Is there a legacy issue in terms of boosting the data quality and implementing these new fields?

Speaker 3:

Absolutely, absolutely. Yes, it's not easy. I mean, when reading all the new fields, as you said, all the changes that are applying First, it's the exercise, own exercise. Each of us have to really understand when to report what. Automating that is not an easy task. So indeed, we have already received questions around this. We personally at RageSDR, we had also to struggle to really understand all the changes. We obviously could bring this to Esma, but we know well this is one of the hot topics that will come. It's already on the desk and it will come more in the future months. The more well you know clients are delayed. Some of them are not up to speed yet. They are starting to test now. Well, some of them have already tested quite a lot, but some of them are now starting to open the testing accounts. So it's now when they encounter, in reality, this kind of issues of doubt. So I will encourage them to really look into this because it's something that takes time.

Speaker 2:

How do you test for some of these fields? Because, for example, package transactions spread, which applies when the price and the currency of a combination of two or more transactions are reported separately but are negotiated together as the product of a single agreement. Now that to me sounds like quite a complex scenario. How do you mock that up and test your reporting systems with that? Do you have to use examples from previous history? In which case, have you got all that data? It seems like the testing challenge is really onerous for market participants.

Speaker 5:

It is.

Speaker 5:

I think that there's no two ways around it.

Speaker 5:

There's a lot of complexity to this and I think sometimes it's very easy from a regulator's perspective to look at market participants and say, well, you should have this data already, you should know it, it should be easy for you to access it and to meet the new reporting requirements. But it's nice fundamental change in the way that clients are using data today and the way their systems are configured. So it's a huge undertaking to get the data and then to put it into the right format and to repackage it and to be able to do that on a consistent basis, to report to meet the immediate requirements, the sorry, the refit requirements. So it is a huge challenge. It's quite easy for a TR to sit there further down the stream. We've got huge development We've had to make around this, but what we do is very prescriptive in terms of either meets the criteria, the validation rules, etc. Or it doesn't. But for market participants there is a lot of rebuilding work that needs to take place in order to meet the refit requirements.

Speaker 3:

Actually, on this point, well, andrew asked how many tests I mean. I can tell you, for the big entities, the test plans are insane. They really have thousands of cross validations or different products or you know transactions, that they are slightly different and each of them have to be tested separately, but we actually try to test all of them. We have a very robust quality assurance team, a testing team that tried to go through all the possibilities, all the scenarios that clients could face. Some of them we just find them because you know some clients have cash histories very particular that they have to report and those, well, they inform us.

Speaker 3:

That's why it's very important now using the testing phase, so you know, clients can learn and build their systems. Plus, we, in case we missed any of the testing scenarios, we could also add it and enhance our system. But it's a common work between the product teams, the front desk, the testers, the developers. It's actually an important team work that has to happen in order to be able to complete a good quality test plan. It's not easy. It takes time.

Speaker 4:

Just to also give you an idea of the complexity of this testing, there is also a test period with NCA's, with the authorities, which comes from now, the month of December, until the end of March. So during that period the TRs are also testing with the NCA's all the process of the reports that they received to get the same feedback and knowledge from the TRs to the NCA side. So it's a really complex and big scope of testing scenarios.

Speaker 5:

Yeah, I was just going to add. It's, by the way, a really good point as well, which is, I mean, in our test environment, the testing is actually two-way. It's really important for us, the clients, to test, test, test, test more which I know we've said multiple times on previous podcasts because that also helps us test our platforms. You know our system to ensure that go live, every scenario, every combination has been double checked and to ensure the integrity of the system. Obviously, we've got teams doing that as well.

Speaker 5:

And the other thing maybe that we should mention is the work and the fantastic work that the various associations have been doing as well. The working groups have been doing in terms of actually looking at the brief fit liaison we've asked, liaison to the regulators and actually looking at how that should be applied correctly, looking at market practice and, if there's any gray areas, reverting back within the Q&As but also implementing best practice. So we're all aligned, going forward into that sort of go live day for any of these kind of areas where we think that there could be a difference in interpretation, that we're all aligned in our approach. I think the work that they've been doing is actually shouldn't be underestimated.

Speaker 2:

I mean, there's a couple of odd ones that struck me. I saw that the valuation block, which is a small block of changes, but there are some pretty juicy ones in that. One of them that seemed odd was the valuation date and valuation time stamp, which apparently should always be the same, in which case you know asking from a non-financial background as a journalist why, if they're always going to be the same, do you actually need them?

Speaker 3:

Yeah, I would say well, you need it because there are modifications as well over the dates. Valuations are reported daily actually, and so I mean it is updated. Actually I mean, and date is one format and then the time stamp it's different. So it's the valuation date it's 12th of December 2023. And then the time stamp it's at 11.45 at CET. I mean, they are really specific.

Speaker 5:

It's a hard one because I know the industry has been complaining a lot about the time stamp and saying that the time stamp doesn't actually work.

Speaker 3:

Yeah, because it's very complex when there are different time zones. Sometimes, depending on the time stamp of the transaction, you move to the following day and then it doesn't match the date because you know if you are in I don't know, in India you have a different time, absolutely you're on a different date, potentially. Yeah, exactly. So if you want a detailed answer it's a complex answer, that's fine.

Speaker 2:

Yeah, and more broadly, we see that there's a change in valuations, there's a change of specific fields, like the Delta field, now for Swapchans and options. You know, it strikes me that they really are trying to cover a very wide and very broad range of products in this regulation, which of course adds to complexity, not just for the reporting side of the market participant but naturally for the TR to process that data and get it through.

Speaker 3:

There are actually so many different products in the financial industry, there are so many possibilities that I think ref it with the increase of new fields, the increase of you know all the changes.

Speaker 3:

They are really trying to be able to aggregate and to get information from most of it. But still, I'm sure in you know, 10 years time we will have ref it whatever in 26 and they will keep trying to go into the nitty gritty because products keep evolving, they keep getting enhanced and more complex every day. So obviously the regulation goes behind and these chains, not only the Delta but many other things, are just trying to again get more information, because that's the whole purpose. So you know, authorities getting information to be able to supervise properly, and we knew in the old Emir there were things that were escaping, actually, that there weren't enough fields to be able to report it properly, and these were some of the complaints from market participants. And now this is an attempt or well, I mean it's not an attempt I think it really improved the capacity for clients to report better, to report more complete information. But still, I'm sure as long as products get more complex and they keep changing, regulation will have to change with it.

Speaker 2:

Okay, moving on now to your own journey this year, because, of course, the last time we recorded a Christmas show, registry Art was still within the umbrella of the Deutsche Bursa Group, and now you are firmly embedded within the sixth group and a whole new way of working, doing business, new relationships, new opportunities. It's been a big year for all of you. How has it been? How has the transition over to the sixth group been for you, john?

Speaker 6:

Yeah, it's been great. It's been great, I mean, I'll be honest with you. It's especially great now we're at a stage where the full integration has been completed because, you know, with the integration, almost everybody within the organisation has additional work on the side of their desk. You know you're involved in projects and various other things, but it's all been done and you know we're looking forward to single ownership. Yeah, everything very positive. And also, I might add, this year we also moved to a fabulous new office in London, which has to be a highlight, I think, for me.

Speaker 2:

Certainly certainly there If you get the chance to visit some Marys acts. It really is a flagship. It's like the difference between the original series of Star Trek and, you know, the next generation. It's that kind of upgrade in terms of the special effects of the coffee bar. On that front, I just want to stick with you for a second, john, because of course your CEO of Registry R in the UK six is a third country in so far as it's outside. It's headquartered in Switzerland, outside the EU. So in a way, do you think there's additional expertise and insights there that can benefit Registry R UK as a country that's participating within but also without the European Union?

Speaker 6:

Yeah, I think, but potentially I mean I think the arrangement between Switzerland and the European Union and the UK and the European Union is not exactly the same, but certainly, you know, there is that awareness and we're able to tap into group level expertise across a number of functions. So, yeah, I'm not sure it's directly comparable, but yeah, as I say, I mean, there's just such a breadth of expertise at group level that we can always tap into.

Speaker 3:

I think at Registry R we are specifically sensible about this because when I joined Registry R and joined in our state 10 years ago by the way, time splice then we were like just a few of us. The ME group was for me at that moment it was a big group, it was a whole day, many entities on it, but Registry R was just a pool of six people. You know we were just working together because it was just the real start of ME. So over these 10 years I have seen Registry R grow massively at all levels, not only people and resources but the structure and everything. But then at that time I thought ME was quite big.

Speaker 3:

Now, with the sixth group, that it's much bigger, it's much complex. There are so much expertise. It's not that we didn't have it before, it's that now it's all massive. So maybe for John or Nick that they come often from big entities, from Deutsche Boards you know it's just a different group but also very, very big. But for me when I started at Registry R, for me my world was my six colleagues and now it's all so big that for me the change and the integration with six, I see it with perspective and it's really amazing and it's much better for me, but it's really complex and all the way. As John was saying, now we can say we did it and it's great, but the job of many people and a lot of effort has come through to be able to be here today.

Speaker 6:

It's actually third of January, it's actually my 10th anniversary at Registry R as well, but anyway, what I was going to say was we shouldn't tell ourselves short either. Because we are Registry R, we are part of that expertise within the group and we now are able to offer expertise on these reporting regimes that didn't necessarily exist before. So it's very complementary. It's about having complementary businesses under the one umbrella.

Speaker 3:

Actually, we are pioneers on things like the podcast, for example.

Speaker 4:

Yeah, totally agree. Actually, I wanted to say that we can see that expertise of Registry R is spread now in the industry. For example, our participation in ISDA Association, the participation that we have done under several webinars and even also in the industry when reviewing the technical standards on MREFID, we have been one of the tier that has presented more questions and more concerns that has been taken by the regulators. So, yeah, totally agree that we are at great added value, also for the SIGT group.

Speaker 5:

When we talk about the integration over the past 12 months, andrew, for me the thing that integrated almost immediately was on the people front. I don't think I ever saw a problem on the people front and look, there's bigger changes in different offices, but certainly in London. Embedding ourselves as part of the SIGT team was very, very straightforward and very easy, and actually we've been working really closely. So if I think about the people in our financial information team, they offer regulatory reporting, financial information, so actually I spent a lot of time with them talking about REFID and the drivers of REFID helping to educate them. You just kind of take it for granted. So I think actually it's been a really easy integration.

Speaker 5:

In that regard, I think the biggest change I've had is just purely on the systems. Any of my clients that listen to this will know the pain in my face for them I had from lugging around two laptops. Honestly, I'm going to be pulled around and trying to sort my back out for the next couple of months, I think. So the fact that we finally went to one platform, one laptop, a month or so ago was great, and that was really the last thing. I think integration itself has been great, and it is partly because big organization and we kind of slot into, I always think, those kind of post-trade solutions. So we kind of got a nice little home there where we fit quite nicely and it works really well.

Speaker 2:

Now, while we're here at the end of the year, we can't help but get our crystal balls out, a little bit early perhaps, but let's have a think about next year. And, lara, I want to come to you because, from a regulatory point of view, 2024 sounds like it's one non-stop party. And of course, I do say that ironically, because I'm just looking at this little list here. We've got CFTC rewrite, emea refit, mifid, refi MIFID and MIFIA refits coming. We've got Dora, we've got Mica Plus. Of course, there are new products entering the market, all of which will have reporting obligations, especially in the field of OTC derivatives. And at the same time, the macroeconomic pressures to create more products are there, because we're in an era of very low remuneration at central banks, we're in an era of excess liquidity and market participants are looking always towards new, innovative ways to optimize their financial efficiency, so to balance their balance sheets and all those other exciting things like that. So what is next year looking like? Is it just a non-stop cavalcade of new regulations and new reporting overheads?

Speaker 4:

It is. I mean there are such a significant number of legislative projects coming you mentioned most of them and in particular, in the U-Side, as you said, we have the finalization of the regulatory framework under Mica and the preparation with the NCA for these new regimes, which will contribute a lot to the crypto market and the investor protector. Also, we have Dora that we will continue to adapt to this new application. Very recently, they have published the latest batch of consultation papers on Dora. That will need to be responded by the beginning of March next year and we will have more and more consultation coming Then, for example, there will be a clear focus on green transition, ESMA will expand the single rule book for sustainable finance and we will have a final report on greenwashing.

Speaker 4:

I mean so many different projects and, of course, one of the key ones that we will have next year will be for the authorities to ensure an effective use of the data. So here ESMA, as well as the FCA and all the authorities, will keep improving data quality, which is one of the key focus for 2024 and the following years, and of course, this is linked with the MIRAFIT and with all these new legislation, which their main goal is this improved of data quality and the way to supervise the data.

Speaker 2:

So I'm guessing if you work in regulatory affairs, you're getting a Ferrari with your bonus this year.

Speaker 4:

Oh, I hope so. Good job. Yeah, I mean what?

Speaker 6:

I was going to say on, that is I think sometimes we will fall into the trap of looking at something like this and you know you've got email refit and we kind of look at it like it's something that can be executed as a one-off event and you know, where we are now is similar to where we were, I suppose, 10 years ago. Technology changes, market conditions change and you know having to consistently update the regulatory reporting framework that's the new norm. That is where we are. It's not something that's going to disappear. Post-refit, there will always be factors that will require additional change to the framework.

Speaker 5:

Yeah, it's actually quite scary. Until the list, I didn't realise how much was going on next year. That's absolutely terrifying, isn't it, when you think of you're a market participant, and you think about it as well and say, actually, most of this stuff isn't even my core business, because my core business is actually on investing, it's on generating revenues. So this is all stuff that has to be done almost on the side, and so then companies are actually got that challenge around how can they drive forward innovation, etc. Whilst they've got to meet all of these requirements? So there's some real challenges. I mean, next year there are a lot of moving parts. I mean, john mentioned technology, and that's the other thing is, I think everyone's struggling to keep in line with all the technological advances, and that's why the regulation is always going to be adapting, because it needs to, because there is a constant evolution that everyone's trying to catch up with as well, and there's always that first mover advantage that everyone wants to take advantage of.

Speaker 2:

It's interesting times and Barbara, I mean, do you find that you have to spend a lot of time making clients cups of tea and saying, calm down, or are they doing okay? Are they taking it? What was the client services desk looking like? Are you getting busier?

Speaker 3:

Absolutely yes. We have seen already an increase in the workload that we receive on more questions because, of course, the reporting start date of refit it's just around the corner. And well, they know they are struggling. You know, sometimes just the silliest thing. It's a struggle because sometimes just connecting and inserting a user and a password because now again we have to fight against all the security fence that we have to build you need to download an application, you need to subscribe to this thing and the other thing, and so just logging into the platform, it's already a big challenge.

Speaker 3:

So indeed, they are sometimes worried because there are so many new things. But just to calm everyone down, it's okay if you start now with time and again you start testing, you start digging into it, not to a right, it would be fine. We have a good team to support. I think at 3GCR we really care a lot about the support we give clients and we have also worked a lot on guides and handbooks and many information that clients will, I believe, appreciate, because when you start working into it, it's when problems come up.

Speaker 5:

Yeah, absolutely. I must say, Andrew, I think it's actually Barbara that needs the consistent couple of teams and just the team and an arm around to say it's okay, guys, it's okay, there's an end in sight. But I mean, if you think about it from an introspection, so the time we're recording this, not when it will go out. We wanted to have a webinar for our clients because we've just done the latest sort of update to our UAT environment. We had to do it quite short notice because of the Christmas period. Now I can tell you haven't seen the numbers Within three days of us advertising that we're going to do a webinar, we've had over 500 clients actually register for the webinar itself and that is the demand, that is the interest that people have in this and that's why we will be doing these every month, going forward to a live date, because we know there is a need to stay close to clients and to support the clients. That's obviously a commitment and things will still evolve over that period.

Speaker 6:

Hey, Nick Barbara's got three kids at home. Come into work is like a holiday.

Speaker 3:

You cannot imagine when I'm going to have kids. I thought these bad parents, you know, when they came to the office just to get dressed, I was like it cannot be so bad. It is true, it is for real. I worked much harder because it's more physical when I was on my maternity leave and the first day I came to the office was like, wow, I can have a conversation, you know, more than one minute just with someone and not having, you know, crossed things coming in, and so, yeah, it's actually, there are a lot of work that you can concentrate on things at home. It's not possible.

Speaker 5:

Can I just say to you I can't even tell you necessarily that it's going to get any better. I can tell you now, for reasons I won't go into on the podcast, I'm currently, for a three week period, a single parent to my 16 year old son. Everyone thinks that it's that easy. He's 16, he's useless If he listens to this. You're useless, luke. And my wife said to me she goes, but think about the one to one time you're going to have. I don't think he said more than two grunts to me so far over a period of two and a half weeks, and he just goes and plays Xbox. So that's what you've got to look forward to.

Speaker 3:

Great, really encouraging. Thank you for that, Nick.

Speaker 2:

Pleasure Talking of things. To look forward to that, does we do have to start drawing our threads together for this first episode of season 10, which, of course, now we're moving to a new monthly format. We have a longer show on a monthly basis, so we can get even more in-depth and more focused. In the run up to Amir Refit's deadline, april the 29th, I want to ask you all what are you doing for Christmas this year? And I'm going to start with Laura. Laura, what are your Navidad plans?

Speaker 4:

Oh, I just want to have great family time and actually have friends coming from Mexico to visit us and spend Christmas with us. So I'm very looking forward to it for them to know the traditions that we have here. It's going to be great.

Speaker 2:

Now I'm interested what are you having for Christmas dinner? Is it bakalao? Something like that? Are you roasting a bird? What's your plan?

Speaker 4:

I don't know about the food today, I don't know what we're going to do per year, but we have a very traditional dish on the 25th Christmas Day, which is miras it's bread Bread. Yeah, just Google it migas.

Speaker 3:

Okay, it's a dish which is basically made with bread, but it's fried with a lot of oil, so it's not good for if you are on a diet or something, because it has chorizo on it and it's really like you know, after that you really need to have enough Because it's very heavy. It looks like very simple bread, olive oil and chorizo, but it's delicious with a lot of garlic and it's very nice. But it's a tradition from you know, back at the time for workers on the fields, so it's to get a lot of energy and not just to eat it and go to the sofa.

Speaker 6:

That's what we do. I think we should resurrect the RegistriR podcast recipe book.

Speaker 2:

Yeah, for sure.

Speaker 6:

That's great.

Speaker 2:

I would be perfectly happy if it was just 20 pages of that recipe right there, because that sounds absolutely delicious, john. What about yourself? Are you going to be stuffing a bird in the oven?

Speaker 6:

Well, might be stuffing someone in the oven. I'm actually doing a 2000 kilometre road trip with my ex-wife and 11 year old daughter, and that's all I'm saying on the subject.

Speaker 2:

Wow, that sounds fantastic. That sounds like an amazing thing. That's a long road trip.

Speaker 6:

Looking forward to it. Yeah, Luxembourg to.

Speaker 2:

Edinburgh and back Fantastic, okay, good, wow, that's going to be great. I have to say, having spent many years living in Scotland, christmas in Scotland is a very, very special thing, but also, I would say, having had Christmas with you in Luxembourg a couple of times, that's pretty fantastic as well. Nick, what about yourself it's you and Luke. Do you have something special planned?

Speaker 5:

No, the whole family's back for Christmas. So I'm going to see the outlaws. So that means I'm off to Derby's. They live in the middle of the country. I'm actually staying in a place called Matlock Bath, which, for anyone that doesn't know the UK even if you know the UK, you probably wouldn't know this place I call it the only inland seaside resort in the whole country. For some reason they've developed a town. It's an old spa town. It's full of arcades and fishing chip shops and normally well, probably somewhere between 50 to 80 year old bikers on Arleigh and Davison's. And then on Boxing Day they have a tradition which I believe goes back over 100 years, where they race rafts down the river and everyone stands on the bridges and we bomb them with flour and eggs and they nowadays which I don't think they had 100 years ago they have high powered water pistols and they shoot you back.

Speaker 2:

So the kids are really looking forward to that, barbara, are you going to be feasting on chorizo and olive oil drenched bread for Christmas, or are you going to be, you know, doing something that's a little bit more suitable for people who don't have teeth?

Speaker 3:

Well, I think I mentioned this last year as well. My family is a great family of cooks. A lot of people love cooking, so there's actually a competition for the greatest dish of the year. Normally on the Christmas Eve we have starved turkey, which is absolutely delicious, and well, there are other. Normally there are surprises around it, but normally it's always around. Well, the turkey is for sure that we always have it, but other delicious Spanish dishes, but not me gas. In my family that's not a tradition and yeah, except for that, you know, christmas around kids is always special, so I look forward for that as well.

Speaker 6:

Yeah, I just want to say as well, I know this podcast has been really nice actually to get the old studio crew back together have a good old chat, but also for the course of this year, just thanks to all our clients and guests who have appeared on the show and shared their expertise with us, and that's really why I liked the two client event shows we did so much. They're kind of like, you know, to make a terrible Christmas analogy it's kind of like a box of quality street right. We've got all of our, we pick and mix of all of our favorite guests. You know, danny Corrigan is a hazelnut caramel, maybe John Graham is around Golden Toffee and Tim Harley what would he be? A coffee cream, something like that.

Speaker 2:

I'm going to say, tim Harley is almost certainly a walnut whip in my book, because he has many layers and you know, all of them are delicious. It's getting weird. Now I'm going to say, actually we should fire out a really big thank you, though, to Fabian Clark, fraser Reed, of course, to Tim Hartley, and to Massimo Salerno, to Alvaro Gascon and Victor Rodriguez Garcia. Of course it was right, laura Rodriguez, sorry, you're here, aren't you? So big thanks to us especially, and also big thanks to all those people who participated in our live event shows and, of course, yes, danny Corrigan. Congratulations, danny, of course. Who's now had the launch party and it's all official. London Reporting House is out there, so do make sure you check them out. It's time. It wouldn't be right.

Speaker 2:

We've we have been pretty brutal to chat GPT all year in this, this last season nine especially, and so I think it's only fair that we give chat GPT a chance to get its own back, and I, earlier this week, asked it to write a message to the audience, christmas message to the audience, in the style of myself. Yes, this is my turn to take the brutal punishment, and I want to. I want you to tell me honestly, I want you to vote. Is it an improvement or not? I know where this is going. I read it and I was I felt pretty horrified. Frankly, I thought I was out of a job. Okay, so just so, chat GPT can get its revenge on me.

Speaker 2:

As the year draws to a close, I, andrew Keith Walker, on behalf of the entire registry, our team, want to extend our warmest holiday wishes to you. It's been another remarkable year, full of challenges and triumphs, and as much as our podcast episodes are a chance for reflection and insight, this season is an even greater opportunity to look back and appreciate the journey we've shared. As we wrap up this year, like the perfect present under the tree, we hope you find time to relax, recharge and revel in the joy and peace of the holiday season. Let's raise our glasses or mugs of hot cocoa to the successes we've achieved and to the exciting opportunities that await us in the new year. There you go. That's chat GPT's version of me. Now, my message was slightly different. It was going to be may Santa bring a whole load of data harmonization down your chimney and also a time machine so you can go back a couple of years and rebuild your systems to be ISO compliant there. Which one do you think is the best message?

Speaker 6:

I don't know which one's the best, but you've shown us how we can save a few quid on the marketing budget next year. I've got to be honest with you.

Speaker 5:

You know I've done this before. I voted for the chat GPT just to be spiteful. I can't do it on this occasion as well, andrew. It was just too generic. That was so generic and boring. Honestly, it just reminded me of a really bad best man's speech. So no, I wasn't a fan. Okay, thank you, that's a good job. We need to have a conversation on the side. I can easily become a fan.

Speaker 2:

Well, thank you very much, I'm going to say. I'm going to say for once, chat GPT, despite the reservations, you deserve our thanks for providing us with so much entertainment on the show this year. And that's it. We come to the end of the year, the beginning of the new season, and, regis, yeah, we'd like to wish you a very happy Christmas. No-transcript beginning of the new season. And I would like to wish you a very happy Christmas of Lysnavidad and Jullio Noel.

Speaker 2:

A froh of Einatzen, a Buantali, a Felis Natal, a Cicun Ferisit, a Schlastivogo, a Rodislawa, a Gudjul, a Gladiagjul, a Chayva Yulula, a Gladiagjuli, a Vesoch Sviat, a Vrolish, a K'fiest, a Sretan Bodzish, a Veseli, a Meri Kuri Sumasu, a Shinging G'kuali, a Meli Coele Sumese. A special shine Krishdig to our Luxembourgish friends. A Felisim Natal, a Krissi and, of course, a Nolag Shona. And please, if I've got any of those wrong, it's post Brexit. I'm not supposed to know any of those words anyway by law here in the UK. And that's it, that's everything. Do join us on our LinkedIn page that is linkedincom slash company, slash Regis-Tia, so you can network with Laura Rodriguez and, of course, with Ababa Ruiz Alonso and with Jon Kernan and with Nick and with the other members of the team. Sign up for webinars and find out more about what's coming up for your Refit Readiness preparations and the things that Registria can do for you with those and now we'll actually have some people actually saying these messages in the proper authentic language, and apologies for anyone who's been insulted.

Speaker 2:

Yes, indeed, again, apologies again, and from that, I guess, all that remains is to give a huge thank you to our guests for the year and a goodbye from our studio crew, without which, of course, we could have no show, and that is in no particular order, starting with the Pride of Spain, laura Rodriguez, thank you very much.

Speaker 4:

Thank you very much, andrew, and we're looking forward for next season, with Barbara back finally.

Speaker 2:

Yes, indeed, and on that front, the nicest and most efficient person in the organization is back for season 10 and her 10-year anniversary at Registria. Thank you very much, Barbara Ruiz Alonso.

Speaker 3:

Thank you, andrew, laura. Merry Christmas to everyone and I'm super happy to be back. It's my favorite podcast forever now.

Speaker 2:

And a huge thank you as well to the man who used to put the canary in the wharf. Then he was in Devonshire but never square. He's now looking off St Mary's Acts the CEO of Registria in the UK, mr Jon Kernan. Jon, thanks very much, thanks.

Speaker 6:

Andrew, wishing all our listeners a very peaceful Christmas and a happy new year.

Speaker 2:

And, last but never least, the voice of reason himself, my most regular co-host, mr Nicholas Bruce. Nick, a very merry Christmas to you.

Speaker 5:

Yeah, merry Christmas everyone, and here's to a fun 2024.

Speaker 2:

And also a big thank you to the producer of the show, of course, liana Sudan Liana, thank you.

Speaker 3:

Thanks Andrew, thanks everyone.

Speaker 2:

And if you are horrified by my terrible mispronunciation of all those merry Christmas messages, here are some real merry Christmas messages from our very diverse Registria team in Ukrainian, german, bosnian, croatian, russian, italian and French. Take it away team.

Speaker 7:

In this time of year. We would like to thank you for your cooperation and wish you a happy Christmas and a great start to the new year. The whole Registria relationship team wishes you and your family a happy Christmas and a good trip to the new year.

Speaker 2:

Great, that's good, and from everyone at the Six Group and Registria, we wish you a very happy holiday season and, if it's your tradition, a very merry Christmas. Goodbye for now.

Regulatory Reporting Challenges in the Market
Delegated Reporting Challenges Under EMIR
Challenges and Complexity of Market Testing
Integration and Expertise in Registry
The Changing Landscape of Regulatory Affairs
Christmas Plans and Reflections