The REGIS-TR RoundUp
The REGIS-TR RoundUp is a hub for regulatory reporting news and views from your leading Trade Repository team and industry guests from across the globe.
The REGIS-TR RoundUp
S10:E6 EMIR Refit Go Live Report - How Did the Markets React?
In this special feature-length show, EMIR Refit reporting experts Tim Hartley (Dir. EMIR Reporting, Kaizen) and John Graham (Senior Dir. Regulation, FIA) join our Head of Biz Dev. Nick Bruce, Head of Institutional Relations, Laura Rodriguez and Head of Client Services, Barbera Ruiz Alonso to review the go-live of the most significant new regulatory reporting regime of 2024. After years of preparation, how did market participants react? Did the new UTI system work? Is the data quality there - and are ESMA and NCAs happy with the results? We go in-depth with our expert panel to review the go-live so far and address the issues that remain too early to answer for sure. Plus, we say goodbye to Barbera after 4 years of being a founding member of the team - and give John and Tim a surprise quiz to keep them on their toes. Don't miss it!
Hi I'm.
Speaker 1:Andrew Keith Walker. Hi, I'm Laura Rodriguez 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 regtech, fintech and trade repositories. Welcome to the Registr Roundup 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 organization. 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.
Speaker 1:And welcome back to the Registry Hour Roundup. We are back and it is May and that means just a couple of weeks ago Amir Refit went live and we have got our Refit show for you. Yes, the post-match analysis Joining us sadly for her last ever show before she moves on to brighter, bigger and more exciting things in the fantastic world of asset management is, of course, nicest and most efficient person in the organization by a long way. Of course. Barbara Ruiz Alonso, barbara, welcome back.
Speaker 3:Hey, andrew, thank you very much. Indeed, I'm moving on, but I have to say it's been a pleasure being part of the RegisDR team, being part of this podcast. I had a great time. I just learned a lot, but, yeah, it came to an end Well, I just have to thank everybody for this time, but I'm sure the podcast will keep kicking in forever.
Speaker 1:Well, barbara, you've set a very high bar for this show, to be honest with you, and whoever replaces you has got some big shoes to fill, which is ironic, of course, because you have tiny feet. Nevertheless, thank you for coming back for this show. And with you, of course, is the voice of reason himself, the man who, without any question, is the head of reason himself, the man who, without any question, is the head of business development and, right now, a man with many, many arms holding many, many phones. It is the very busy, mr Nicholas, bruce, nick, thanks for joining us.
Speaker 4:Always a pleasure, andrew, and if Barbara's obviously the person who sets the high bar, I'm the man who sets a very low bar, which hopefully will help whoever comes in.
Speaker 1:Okay, yes Now, nick, you have been super busy. Obviously, go live is a busy time for the head of biz dev, no doubt, but you're looking very well on it actually. Is that a tan, or is that just the color you go after white?
Speaker 4:Yeah, to be fair, I'm not sure when this one will come out, but I'm hoping the weather will last. We've just had that gorgeous weekend. It's been 28 degrees in London, so I'm a typical Englishman. I've gone out there. No tan, sorry, no tan. No sun cream, you know, just bearing my all to the weather, and it's been fantastic. It's great to put shorts and flip-flops back on again.
Speaker 1:It certainly is. And on the subject of shorts and flip flops, someone who never wears them in the office and is always a sartorial pinnacle, the pride of Spain herself, of course, the head of institutional relations for Registria, it is none other than Laura Rodriguez.
Speaker 2:Laura, welcome back, hi, andrew. Thank you very much.
Speaker 1:How are you? I'm very good. I'm very good. It's good to see you again. I was very pleased with our Dora show. As a tech guy, dora is my jam, so that was very exciting. How has the last few weeks been for you? Has it been super busy?
Speaker 2:sad, but at the same time happy, but of course now, uh, the only way for barbara to keep on track on all the news and the information will be listening to us every month. So now on the other, side.
Speaker 3:Exactly that's why you have to keep working in this okay, that's good.
Speaker 1:Yes, one more listener. We we celebrate everyone that comes to the show and, talking of which, that's our virtual studio crew. But we couldn't do this show without two very special guests, old friends of the show that have been on before, two men who, between them, have forgotten more about regulatory reporting than most people ever learn. Yes, I think that sounds like a good thing. I'm not sure if that's come out the wrong way, but joining us, of course, someone who needs no introduction if you work in the field of regulatory reporting Tim Hartley, who is the director of EMEA Reporting at Kaizen. Tim, welcome back to the show, thanks for having me Great to be here, thank you.
Speaker 1:It's great to have you back, tim. We have a few little trivia questions coming up for you later on which we're going to drop in amongst the top flight analysis. There's going to be a few questions about breakfast sausages. If that's okay, we like to try and keep you on your toes. Sounds good, good. And joining Tim is again someone else who's an old friend of the show and also someone who knows everything there really is to know about reporting for the futures industry, and that is the Senior Director of Regulation at the FIA, John Graham. John, welcome back.
Speaker 5:Thank you very much, andrew. Good morning everyone. Huge credit to everyone for creating this podcast, an enjoyable podcast on reg reporting, very successful. So pleased to be back, thank you very much.
Speaker 1:Well, thanks, thanks for coming back and so that you don't feel left out, we have also got a trivia quiz for you, uh, but your specialist topic is going to be bruce springsteen and the e-street band, so we'll be dropping those in as we go, but we need to get on with the big news story a mere refit which we've been talking about for a couple of years, and we've explored all the potential issues. We now get a chance to actually sit down and talk about the real issues, what went well, what didn't go so well, and to set us up for this. I want to come first to Laura, because you're head of institutional relations. You're the one who is the best friend to all the regulators in the EU. You're involved and get a view from it, from their side. I want you to frame it with that.
Speaker 1:So how is ESMA measuring this success? What are they looking for now? How have they reacted now? What's the news from the regulatory side? Because really they're always the voice that's missing from these shows, because they tend not to do podcasts and that sort of stuff. So what's the inside view? How's it gone for ESMA?
Speaker 2:Good question, andrew, but I think the important here is not how ESMA has reacted to the go-live or how the NCAs have reacted to it.
Speaker 2:It's more how the market and the reporting participants have reacted in general, how they have approached the first days, the first issues and the source stoppers and the capacity they had had to overcome any difficulty that they might have identified. And this is something that we will discuss now. So that's great, and I also think it's really important that at this very moment, the market participants had a clear communication with their relevant direct supervisors, with their NCAs, because during these first weeks they will be cooperative and participative to help them to find this stability of the reporting requirements, them to find this stability of the reporting requirements. So this is a great opportunity to establish relevant contacts with the NCA's and to show the commitment to comply with the new regime. But of course, if you ask me about the specific reaction, probably we will still need to wait some time to have any news or public statements from their side to really know their views on the success of the implementation. It might be too early yet, but I'm sure they will give us the information in some time.
Speaker 1:Are there any sort of rumors in sort of time? Are there any sort of rumours? You know, is anyone you know doing their fruit over the data quality there in Brussels or Luxembourg? Is it running smoothly though? I mean, come on any hints you can give us. Are they happy or not? I realise I'm asking you to make a massive commitment on behalf of major European financial institutions here. Live on a show, so I mean, don't no pressure, but you know, do you think it's gone well?
Speaker 2:I think it's a. I won't answer because I don't have I don't have, you know the full picture. It's really difficult, but, on my view at least, I see that there is a lot of cooperation from the authority side and this is really good and clear that they want this to go smoothly and well.
Speaker 1:So, yeah, Okay, fantastic, Now we're gonna go. Then we're gonna jump from the regulator side and I think I think we all read the subtle subtext there, which is actually is going pretty well and go straight over to the man who has quite literally got his ear to the ground. In this case they're in the city, Tim Hartley, so Tim Kaizen have got a massive network. You're familiar with a big picture of how market participants are reacting to Amir and how things are going. So I want to come to you and say, from the market participant side, is this what you expected to see when it went live? I remember us having conversations when SFTR went live and everyone was surprised that it went a lot better than people were expecting, but of course, it was a lot smaller. So what about this? Have we seen good reconciliation rates? Is there a high rate of rejections? What about the issues that we were talking about over the last couple of years? Have they gone smoothly?
Speaker 6:Yeah, there's lots of things in there, andrew. The other thing with the SFDR is that there's a much smaller array of product types to be reported, and so actually for me personally, it wasn't that much of a surprise that data quality was higher or it was necessarily easier to get those trades in under SFTR. What we've seen under Amir Refit is such a large array and a large complexity of change under Amir Even for clients that do Amir reporting in the old style of Amir, to adhere to everything other than Newstar is a big burden. There's lots of things to take into account. There's lots of new lessons to learn, and things that we spoke about over the last couple of years are, for example, almost every single field changed, and that's a big change for an IT resource. Also, we've got hundreds of pages of guidelines that we spoke about before already. That changes the interpretation, and sometimes it's good, and sometimes it creates more of a grey area, and so actually, in actual fact, for most firms that had an EMEA reporting obligation and still do today, they see EMEA refit as a new reporting obligation, even though they were doing EMEA reporting already, and so it's been a real tough task. So I'm genuinely impressed at how firms have gone and how they've taken to all the changes that have been there. I think positive things are the participation rates for trade association groups and different forums that the trade repositories have put together. So that level of communication and questioning things and coming to a consensus on what's good and what's bad and how we should report things, that's been applauded by me. I think that's very, very good, but it should be underestimated the amount of change that there has been from Irifit.
Speaker 6:And then back to your original point in that question, andrew, measures that firms should be paying attention to, measures that firms should be paying attention to. I see on LinkedIn and other social media, people paying a lot of attention to the ACNAC rates, so the acceptance rates and rejection rates on, for example, a trade depository. I think that's not worth paying attention to at all. I think what you need to pay attention to are the late trades. So how many firms um are reporting those trades late because they've got an issue with the, with the actual submission itself?
Speaker 6:Um, rather than, if you get your trade rejected, let's say your submission is rejected, all you're going to do as a firm is correct, that rejection and resubmit, so great. So, um, acceptance rates should be 100 and um, so I don't pay too much attention and I advise other firms not to do that. The other thing as well is to look at the inter-TR reconciliation rates and so how your trades are matching up with your counterparty's trades, and the tricky part on both those two stats is that they will take a little while to come out, whereas the ACMAT rates firms are happy to talk about those. Tricky part on both those two stats is that they will take a little while to come out, um, um. Whereas the act map rates are um, firms are happy to talk about those, I think mainly because it's easy um, but it's the late trade and the ncr reconciliation success rates that firms really want to pay attention to and, if I'm being suspicious, I expect that being what the national competent authorities um will be paying attention to as well.
Speaker 5:I was just going to ask a question because we're two weeks out from go-life. Going back to Tim's point with regards to the acceptance rates at the TRs, for what it's worth, I do agree with him when we're so close to go-life we're only two weeks and we're looking for those stats to try to give an impression as to the success rate of implementation plans et cetera. Would you completely ignore acceptance rates, tim? It seems a bit harsh. Or is it potentially a good news story that can indicate potentially the direction of travel with regards to the success of refit implementation plans?
Speaker 6:Yeah, I've been called many things for mere reporting. Nice is not one of them. But no, I think firms can take a level of comfort from ACNAC rates. I think that is true. I think it's a bit of a soft stat, is what I'm saying. So you're right in that it is hard to get everything into the TR with this amount of change. So you can take a level of comfort from that. Firms that are getting almost everything accepted first time, first submission, try that should be applauded, because there are still a few tricky parts of the validation rules. For example, when you're looking at notional schedules and things like that. And notional schedules and things like that and prior UTI and things like that, it can get tricky. So, yes, I agree there is a level of comfort in that, but for me it's not the true picture and that's why I want firms to focus on the big hitting stats, whereas the other one is a nice to have.
Speaker 1:So, on that front, though, I want to come to you, john, and ask about a few of the unknowns that were sort of floating around in the show that we did last season, talking about the challenges that might be there for the futures industry. Beyond that, Things are still very early, but we did talk a fair bit, didn't we? About position data, for example, and those sort of tricky things. So, position data timestamps there are those things to consider Plus, of course, the largely tested but hadn't been deployed at the time the UTI system from Anadies B. How have these things panned out as planned or not as planned? And also, are there any things that we weren't expecting to be a problem that have shown up to be a problem?
Speaker 5:Yeah, sure, I think first and foremost I'm going to start off on a positive note and it's really picking up on what Tim mentioned about the size of the task that the industry faced over the past 18 to 24 months with refit. Refit was huge, wholesale changes. So we are guilty within our industry. Regulation markets move so fast, regulation moves so fast we never take the time to sort of tip the hat and say well done to anyone. There's been a lot of folks in our industry that spent days and days and months preparing for a refit, so I'll be the first to say well done to the industry and we're all collectively working through teething issues and problems that we're seeing. When we hit March of 2024, a lot of firms, their implementation plans, their releases, their IT updates, they were locked in place. They couldn't really move that much and, as a result, over the sort of six weeks out from go-live, the focus area really became transition plans, became transition plans, and what I mean by that is transition plans over the weekend of Friday, the 26th of April, into Monday, the 29th, go live date. The reason I mentioned this and Nick might be able to speak on this, as well as the fact that obviously TRs were switching over to MIR refit. They were doing that over the weekend and, as a result, tr environments came down. They closed on Friday evening, some of them midnight on Friday, some of them a little bit earlier. What that meant for us is that in the ETD markets the majority of firms report Friday's activity and Friday's end of day positions on Saturday. They weren't able to do that because the TR environment was down. As a result, firms were then forced to report Friday's activity on Monday. So, in a long-winded way, what I'm getting at is Friday's activity needed to be refit compliant and if I was looking at this very blunt, it almost brought the go-live date back to Friday, the 26th of April, because you needed to have all your data elements for refit compliance ready for Friday's activity. That became a huge focus area for us during the second half of March and then all through the course of April.
Speaker 5:Another point that maybe naively we discovered and focused on close to go-live was in relation to flat positions. So when a position goes flat under the previous MA rules, many clear members exited that position, didn't report, and the CCPs took a different approach. They retained that position, reported daily valuations. That wasn't going to fly for MA, refit ESMA, to be fair to them, were very clear in their expectations in that you have two options If a position goes flat, if you exit out of that position and if it reopens or is retraded into, you're expected to report that with a new position, uti or your alternatives, as the CCPs were doing. You can retain that flat position, report daily valuations. So a lot of the clear members had to go back and identify those flat positions and try to find a way to for want of a better term revive them, bring them back to life. Some firms were clear members were successful on that Before GoLive, others not so much.
Speaker 5:So again, a bit of an issue that we were dealing with and then, finally, another point, and then I'll just finish up on your point execution timestamp at position level. Our argument for many years is the fact that positions are not executed. So under the previous EMEA rules we were leaving the execution timestamp blank. Obviously, again, esma to be fair to them, were very clear in their expectations in the fact that they want the execution timestamp at position level to be reported with the execution timestamp of the trade that first opened that position. We needed to go back and find a way to identify the trade that first opened that position. We needed to go back and find a way to identify the trade that first opened that position, to try to report that, preferably before refit. Golive Again, some firms were successful in that, others were not, but that was a teething issue that we're dealing with.
Speaker 5:And then the point and maybe Tim might be better to speak about it but in relation to the UPI and the GoLive UPI, it's very much more of an OTC element and doesn't really touch the ETV world. So I would leave that maybe with Tim and my industry colleagues at ISDA as well. But certainly what we're getting at, andrew is teething. Issues were to be expected. We are building a list of those and we're working with industry stakeholders to try to resolve them over the coming weeks.
Speaker 1:Okay, so that feels again broadly positive, like nothing too unexpected has occurred. I mean there haven't been any major curveballs yet. But of course we've seen the regulator side. We just had a little chat about the market participant side. What about the TR side? I want to come to Nick and Barbara now and ask you how it's been for you, because of course, from the TR's point of view, you have to be producing seven different kinds of daily reports now. You've got a whole load of new systems you have to implement for servicing the data requirements of refit. There's 209 fields that need to be piped through to you. That again have got various challenges, john just pointed out you know time stamps and things that used to be left blank.
Speaker 4:We've got a range of fairly tricky, deep technical stuff at a massive volume which doesn't sound like you've had an easy couple of weeks in the sun Because I think there's a few things I'm completely agreeing, actually, with what the guys said, particularly in the bit where I think john said to tim he's being a bit harsh around the act rates. 100 agree with that as well. Um, because I think where we are, as you said, it's been a huge challenge for the industry and trs weren't immune from that. It meant huge changes on our side as well. I mean, we used it we've talked about it before as an opportunity to effectively launch a brand new platform and that, for us, felt like the right moment. But there was a huge body of work around this.
Speaker 4:And now for me, the way I look at it is the number of things is looking at. What does success look like? As we said, at the moment, a lot of the stats. If we're looking at things like you know, regs, etc. That's going to come out down the line. So we don't really know that yet. We need a settling down period and that will be we know will be the measure going forward. That's what the NCAAs, that's what ESMA will look at. But the ag rates are a great indication because actually, when we were going in, we were sort of heading towards go live. The whole industry was worried about market participant readiness. We were seeing the testing rates were extremely low up until the last three months before go-live. So clients were really pushing their testing programs quite late in the day. So when we're looking now at rates that are in the high 90%, you know that's actually a very good position. That's probably better than we were expected, if I'm being honest, which is a great indication of what the industry did.
Speaker 4:But there were a lot of challenges that we've seen around that I mean john was absolutely right. It was incredible in the last couple of weeks that kind of realization that I was having with clients where we're talking about the data for the 26 and that plan around. Well, how do we report that? Because if the window is not there to get that through on the 26th because of changes, the transformation and also things about the time stamp etc. Couldn't be reported over the weekend. We we actually pursued that. There were discussions around that which meant it had to be reported on the monday and then it had to be reported to the new standard. That's a challenge, especially when you're really set in your programs as well. So we were having a lot of consultations with clients around that, you know and these things had.
Speaker 4:I suppose there was a lot of things where in planning, you always look at the bigger picture and you don't always look at those small kind of the impact of how am I treating my Friday? So my wind down, my hand over, and then that opening up on the Monday, what resources? And from our point of view, one of the big challenges we've had as well was, I think a lot of people presume, well you know what it's going to look like post-refit because you're already doing the mere reporting today. But this comes back to the size of a mere reporting relative to SFTR, a completely different beast, and the type of entities you're dealing with is a whole range, you know, from CCPs, the tier ones, through to corporate treasuries. Everyone's got a very different journey and what we found was, when it came to go live, the kind of just even things like the reporting spikes that you normally have, the busy periods of the day it's all shifted because clients were still running parts of their projects, they were still proofing elements of their reporting.
Speaker 4:Some, in the first few days, reported late because there were certain things that they hadn't finished or certain challenges that they came across only in production. So what we were finding as well was, for us it was trying to make sure, and the challenge of optimizing our platform, because we were getting spikes at times we weren't expecting them. You know, we were seeing peak flows on what normally a quarter days as well. So I think there's been there's been a lot of challenges that we've seen a lot of interesting sort of dynamics to this that we've navigated together and I think over. When you look at it and we look at those early stats, it's actually been been really encouraging. I mean, that's just my kind of high-level view, but obviously Barbara's probably more in the weeds, speaking with the clients and sort of seeing the day-to-day stuff. So I mean, barbara, I know what your view is as well.
Speaker 3:Well, yeah, I basically agree with everything that you've said, and also John and Tim. This has been huge for all the industry, not only the tier, obviously and we've seen a huge variety of preparation, also amongst the different clients. So I cannot concentrate, you know, in one single thing the issues we've been experiencing, because some people had more issues on a certain fields where others, you know, just had passed all the initial for example, initial connectivity issues, because we completely changed our platform and maybe, you know, some people were still working on that at the very few days before they go live and others went through that three months earlier. So it's been huge. But we also have to bear in mind that here refit broad changes, actually from still 2014,. Things that couldn't be changed since then, that now you know, pursuing the quality of the data, we are still fixing, like, for example, the CLC codes. There are still codes which are not LEIs, entities that are identified or individuals not identified with an LEI, and also many entities had to work on this. So this is a very long way.
Speaker 3:As we said, it's not that we can reach some big conclusions still today, because it's very early, but what I see is that you know the big thing is working, which, to be honest and laura can correct me if I'm wrong in my experience what esmond regulators are following or are pursuing at this stage is stability and the big thing to be done. There are many little items that can be fixed going forward, but these days, what we need is you know to make sure the big part of the reporting is being done, that entities are connected, that you know everyone knows what to do and how to modify the things, how to update, how to correct the different stuff, and there I think we are. You know we are getting there and we're doing a good job. We are actually also on our side adapting our platform to all those things that we can hot fix and that we can easily fix, and this is what we are targeting these days.
Speaker 1:So, yeah, very big uh, you know variety of of uh things, as I said, but I I believe we're doing well okay, which this brings us, I guess, to the point we're at right now, which feels a little bit like are we waiting for the other shoe to drop, as they say, as everyone sort of, is this the calm before the storm, or is this the calm before the storm, or actually is it going to be a bit of an anticlimax and everything's going to carry on business as usual, it's all fine. So I want to come to Lara and I want to come to Tim and John on this one, because I want to know what the next milestones are, and it's very easy to think okay, this is a major event, it's on the horizon of progression, of the go live, because it's not like throwing a switch, is it? It's a bit more of a transition. Tim, I want to start with you on that. What are you telling Kaizen clients?
Speaker 6:Yeah, I think there's a lot to be getting on with Many firms. I think I agree totally with Barbara's point that the big picture is that trades are getting in and that is it's really, really important. I think for many firms there is a large book of day to work where firms are looking at the data quality. They're looking whether what they've reported not just meets those validation rules but whether it's been done in an accurate, timely, a complete and consistent fashion for all the reporting they've done. And those checks are really, really important at this stage as we're going through, you know, this first kind of transition period for, uh, in mere refits. There's lots and lots to do there and um and because all those things we mentioned already, the amount of change there was going into a mere refit. It's not possible to build everything that you want and to test everything you want for day one. So the day-to-book of work for almost every single firm involved is a good chunk of work to do to make sure your rec's in place, make sure your assurance testing is in place, make sure that you've got checks and balances on your reference data and things like that Not small tasks by any means.
Speaker 6:So lots and lots of things to do there and indeed I think we've alluded to this a little bit along today's chat in that we haven't seen all of the issues yet, all the niggling first issues yet for a mere refit, because it's only been the first small period, as firms trade different types of derivatives and indeed different lifecycle events happen that will bring more issues out of the border would work.
Speaker 6:Also, as firms go through and change their data from existing derivatives in the old format that need to be amended to the new format, that will bring challenges as well and I think come uh, come to the surface as time goes on so as as we move forward with the rest of this year for a mere refit, as um under for eu firms need to be looking to make sure that their data is totally fit for purpose. Um and for many, many firms listening to this podcast, they will have that uh reporting obligation in the eu and in the uk and uh, whilst the two regimes are fairly similar at the moment, any changes, any improvements they make to their emir reporting under the eu um will have massive economies of scale for the uk reporting and so it's really all to play for at this stage, which is great.
Speaker 5:Completely agree with what Tim said there and I'm always trying to be certainly on this podcast anyway optimistic. The day two book of work is huge. You just look at that high bar where the bar is for successful reconciliation. Look at that high bar where the bar is for successful reconciliation Under refit. The volume, the amount of fields that are being reconciled has increased seismically. So there is going to be continuous corrections and amendments and adjustments to ensure the data quality is there.
Speaker 5:Where my optimism takes a little bit of a hit is as Tim mentioned there. So the four and a half months before refit go live in the UK will be upon us in no time. It doesn't help the fact as well that we take in the summer break, the summer holidays, as folks hopefully take some time off as well. So that 30th of September date will be upon us in no time. So where firms have a reporting obligation under EMEA in the EU and the UK, I think the pressure on resources will be sizable over the next few months and that's a tricky point.
Speaker 5:One thing I would be interested to hear from the group here is how much of my work if I'm a market participant, how much of my work to prepare and implement for eu refit. How much of that can be recycled and used for the uk? I would hope again, potentially naively, optimistically, I would hope a lot of that can be recycled. But we do have to account for the fact that there's nuances and differences, um, some differences between the two regimes, but I don't know if anyone's got a wild figure. I I'm for white tim. Would you disagree if I said something like 85 of my work for eu refit can be recycled for uk?
Speaker 6:it's probably a little bit higher. We've got some q a coming out from that's just been released from the fca and bank of england, um, which has got some interesting things in there. Um, the fca have specified that they don't think those changes would need to be implemented prior to UK refit going live, and so I think I think it's north of 85 percent for sure, and so, like I mentioned before, this real economy is a scale there nervous on that point, in that firms um shouldn't look to give up their regulatory change resource until, um, you know uk briefings gone live and you know, looking at the other g20 regulations as well, um, you know of which, for example um, uh, there there is print thread coming up, but also, uh, asic and mass in october. There's lots of change going on there. But for UK, any attention that you give to data quality and any improvements that you give there are really, really going to pull big benefits come later in the year for September for UK. So I totally agree.
Speaker 3:Barbara, yeah, from a tier perspective, I fully agree. I mean our intention in terms of the platform and the you know the structure of all the database and everything, is just to replicate as much as possible also for the UK, not only in our benefit, of course, to just reuse everything we have, but also in the benefit of the clients. So I'm not sure I dare to say a percentage, 85 or bigger, but yeah, it will be pretty high and it's just a question of, you know, adjusting to the differences with the FCA, but that should be minor. So I agree with Tim that all the work that entities are doing these days to fix and to adapt to the European regulation, that will be worked that could be also used for the UK.
Speaker 4:Yeah, and I was just going to say I mirror that the conversations I have, I think, platform-wise. You know that there is very, you know there are some variances, but it's small. So maybe some of the other considerations are approach things like errors and omissions reporting et cetera. But from a TR perspective, when you're talking purely technical, I mean, there's very little change. So I'm with John, I think yeah, it's definitely higher than the 85% in that regard, and that seems to be the conversations I'm having as well.
Speaker 1:Now I want to come back to John here for a minute, because in a way futures are kind of new here, aren't they? They are now in scope. The expansion, I suppose, for the industry, or the change of the industry maybe, has been felt most keenly in the Futures Association. I mean, what are your members saying? Are they finding Emir Rifa is onerous or, you know, have they found it a fairly easy transition?
Speaker 5:It's brutal. I'll complain a little bit here. Emir is an OTC reporting regime with ETDs bolted onto the back, but I've been complaining about that for 10 years, so forget that. But the task that firms have faced over the past couple of years, like I mentioned, it's been huge. So I don't know if congratulations or fair play to market participants because they put in a hell of a lot of work over the past couple of years to get where they are.
Speaker 5:I mean, one of the benefits that we have, andrew, as a trade association is the fact that our membership covers those clear members, as I mentioned, ccps, trs and obviously the third-party solution providers as well. So that element of collaboration really is there. And others might disagree, but I think in our industry the REG reporting space is one of the most collaborative spaces. There's no real winners, if you know what I mean. There's no real benefits of being way in front of another market participant. So the working groups that we have for example, we have the FIA MIR Refit Working Group and we also partner with our friends at each European Association of Clearinghouses to bring together clearing members and CCPs. That collaboration really is priceless. It's a forum to raise those questions, engage with others and work through the challenges over the past couple of years and the benefits and the output of that has been industry best practice documentation. We've built on ESMA's guidelines where they set out certain scenarios as well, so trying to have industry consensus in the face of huge regulatory change. It's invaluable so that work continues and, as I mentioned, sort of our day two work because we have elements of day two work as well is sort of to gather and log those issues that I mentioned. I'm going to try to be optimistic again in the fact that I feel many of the issues are teething problems, and here's an example Obviously, the CCPs, working in collaboration with the industry, prepare the CCP harmonized file.
Speaker 5:What that is in a nutshell is an end-of-day file containing key data attributes that Clear members use to enrich their reports in order to submit in compliance with Article 9 of EMIR. What we saw post-go-live is some delays in receiving those files from the ccps. That obviously puts strain on clear members ability to report in time for what it's worth. We were hearing delays of upwards of 12 hours. Then that improved to six hours and I think over time we will um, hopefully eradicate those delays, but that's what we were seeing over the past couple of weeks and Nick's maybe going to beat me up for saying this but also one thing that we were sort of discussing and dealing with is elements of inconsistent validation rules across the TRs, which happens. It's the nature of the beast when you look at the size and volume of reportable fields under refit, but what it means is industry best practice and industry consensus. Obviously there's a pitfall there where the TRs maybe have implemented validation checks in an inconsistent manner.
Speaker 6:Again, those are only a handful of fields, so I hope they again can be resolved through communication with with the trs yeah, I'm gonna disagree with john patrick on on one point there which is really important um, um, so, uh, it is a subtle one, but it is important. So with I think there is benefit to being out in front and having make to make sure that your, the quality of your data, is as good as it can be. I think if I'm going to correct you, I'm going to say that there's a comfort in being part of the pack and having a consensus in what to do with your reporting and how that reporting should be. But I feel quite strongly that firms should be striving to make sure that their reporting is the best it can possibly be, striving to make sure that their reporting is the best it can possibly be, not striving and that's not what you're saying but not striving to make sure that what they're doing is matching the other firm.
Speaker 6:For example, should we all perform FX swaps as two submissions just because the other big sell-side bank down the road does FX swaps as two submissions? The answer is definitely no. You should make sure that you're adhering to the regitude details, you're adhering to the level three documents, and so to be out there in front is a really honourable and worthwhile thing to strive for, because it makes that quality of data much higher. And when we talk to the Bank of England and the ECB about their data and the things that they're using it for, all of a sudden it becomes quite scary If the Bank of England is using this data for monetary policy committee meetings, all of a sudden, that impacts people's mortgages, that impacts policy decisions. That do impact not just people in the financial sector but the rest of us, and so for me, I think it's a goal worth striving for.
Speaker 1:Well, I wanted to. I mean, sadly, we have to actually tie this together Because we're coming to the end of our time together and I think actually what we should be doing perhaps is looking forwards at the calendar of events and workshops and conferences that are going to be coming up from all of your respective organisations, because anyone who follows these topics on LinkedIn will have seen you all in quite an intensive program of events working group meetings, conferences where these topics and solutions for the problems people are encountering are getting actively worked out. So it's probably the most effective way for market participants to address their issues if they're not attending already. So I want to just go around quickly and see what are the key sort of milestones coming up events-wise. Laura, I want to start with you on this because I'm guessing there must be some that are getting held from the regulator side.
Speaker 2:Well, actually something that already came a few weeks ago was the data quality report from ESMA from last year.
Speaker 2:It was like a public discussion or webinar where they presented the report, and it was quite interesting to see how this report was highlighted, because it was focused on how authorities are making use of the data, how they monitor the trends, how they monitor the exposures, and it's where you can see that the I mean summing up all the discussions that we have having here today that the data has sufficient quality to be used now for these purposes, that the data has sufficient quality to be used now for these purposes, which, of course, for REFID.
Speaker 2:We will need to make more efforts on the data quality issues that will come, but I think it gives the comfort to the authorities that soon enough, they can enhance their monitoring supervision with the quality of the data that they will have in the future months with REFID. So I hope we receive more information from authorities on this regard. On upcoming monitoring of different activities they are doing based on data driven from EMIRA and any other regulations. Yeah, and of course, there will be many other events coming from them, different regulations, but I'm really eager to see what's their views on the evolution of this one.
Speaker 1:Okay, great. And what about from the Kaizen side? What's the events program? What's the next key thing that you're doing to address issues for market participants, event participants, event wise?
Speaker 6:yeah, so we've got quite a few events coming up this year, um, and but most of them are for kaisen clients and some esteemed guests, so any trs that are nice to us can come along as well. Um, but we have a kaisen conference in june, of which where we have various market experts talking on not only how Emirate Fit, for example, has gone, but also looking forward to UK Emirate Fit as well. We have Bank of England and the FCA giving their opinion and talking about some of those changes as well, as well as a vast array of buy and sell outside banks at that particular Kaizen conference. So we're really looking forward to that. There's a lot of change here and we want to hear where firms are having trouble, where we can help firms and also to give feedback on industry consensus to the marketplace as well. So that's really useful.
Speaker 6:We're also doing continuing our series of uh, what we call cars and community forums where we give the opportunity to talk about different issues that we have. It's a slightly different spin, for example, uh, what john has for his trade association with the fia, but it's a small group, that where we look at um things that want to have a bit more discussion in depth and that's really really good, and a few other events will be in Stockholm with Nick in the middle of this year as well, talking again to those firms also about the difficulties of EMEA and how it can help and to try and clarify some things that are tricky. So definitely lots coming up as firms. You know, as everything settles down, they've started to do the reporting and they start to see other issues and what things they need to be addressing. Lots of things in there and, like we said before, any changes now to the quality to improve the data quality is really really worthwhile at this early transition traditional period, which is tough. It can't be underestimated how tough it is.
Speaker 1:Okay, and John, I'm guessing you've got a full program ahead. We often see you speaking at events and coverage of your sort of viewpoints, so I mean, obviously I'm guessing the FIA also has got its own events coming up and working groups. What's the next few weeks looking like for you?
Speaker 5:Well, this afternoon sees the FIA, each working group that I mentioned earlier. We're meeting to discuss post-refit teething problems, etc. Probably the biggest one. Very much it's comfort season we're coming into, and the biggest one that I would mention is the fact that IDX kicks off inon in mid-june I believe it's the 17th to the 19th of june, um, where I'm delighted to say that mr refit is a focus topic for us and we have a panel entitled mr refit, the final countdown, and I've been informed that we're going to be playing the europe song uh, final countdown as we walk on stage.
Speaker 5:I know right, so, and I'm delighted tim's going to be on the panel, nick's going to be on the panel, we're going to have representation from the fca, from london metal exchange and also from deutsche bank and and the plan really there is to look at implementation plans how can you prepare your business for refit go-live in the UK in September? And then also another point lessons learned, really, sort of post-refit go-live in the EU. How can we learn to make it a smoother go-live in the UK come the end of September? So, really, really looking forward to that panel and having Tim and Nick on there with me as well nick, what have you got coming up?
Speaker 4:from our side, it's a case of it doesn't stop, because obviously we've got the uk coming up. Um, a lot of what we'll be doing over the next few weeks as a team is actually getting out and seeing clients. So there's this period where everyone's betting down. That is very, very important for us to be in front of our clients. Then post that. Next month We've just got to finalize the date we will be doing another webinar which is just focusing principally on the UK go live, but also looking back at the launch and just looking at what are the lessons learned, things like that. We're also going to be hosting in july a uk breakfast as well around refit.
Speaker 1:So those are just some immediate things, and obviously our friends over at kaizen and the fia are going to keep me busy as well, which is great stuff in that case, we can now move on to the fun portion of the show, which is a trivia quiz challenge between two titans of the industry uh, john gray and tim hartley. Who can win the rapid fire round? Uh, on their specialist topic. I'm going to start with you, john. Yes, okay, questions are coming up. Okay, here's your one minute chat. I was going to do multiple choice, but I think that's too easy so, so nervous we're actually going to find out if he's a proper fan.
Speaker 4:Now this could just be talk. This is it. This is the test.
Speaker 3:You have to tell the listeners that he's stretching, he's getting ready for the quiz and everything.
Speaker 1:John, your minute starts now. In what year did Bruce Springsteen release his debut album? Greetings from Ashbury Park, New Jersey? 1973. Okay, Sorry, 72. Which Bruce Springsteen album Features the song?
Speaker 5:Born to Run, born to Run.
Speaker 1:Yes. What was the name of the saxophonist who was a prominent member of the E Street Band Until his death in 2011? Lawrence Clements? Yes, which song did Bruce Springsteen win An Academy Award for Best Original Song? Please, philadelphia, correct. In which year did the E Street Band? In which year did the E Street Band? In which year was the E Street Band officially formed? 1975. 1972. Which song features the lyrics you Ain't a Beauty, but hey, you're Alright. Thunder Road, correct. And finally, how many Grammy Awards has Bruce Springsteen won as of 2020?
Speaker 5:Oh, that's a good question. I'm going to guess this, I'm going to say it.
Speaker 1:No, the answer is 20.
Speaker 4:That is impressive. The funny thing is I'm looking at Tim and just the visual that I've got. I reckon this man knows his sausage.
Speaker 1:Okay.
Speaker 4:I don't think this is going over, yet I was thinking the same.
Speaker 6:AI Tim is pretty good at sausage out here, so yeah.
Speaker 1:Okay.
Speaker 1:So I'm going to say now, john, that was almost a perfect round, almost a perfect round. You only got one wrong, sorry, two wrong, so well played. Well played, john Graham, fantastic score. Okay, Tim, your specialist topic is breakfast sausages. I can't believe I'm doing this to a senior analyst in the industry. There you go. It's the silly season, it's the sun. Okay, tim, your minute starts now. Okay, what type of meat is traditionally used in British sausages commonly served at breakfast? Correct. Now, ok. What type of meat is traditionally used in British sausages commonly served at breakfast? Oop, correct.
Speaker 1:Which country is known for a variety of breakfast sausages called Weisswurst? Germany, correct. In the United States, what is a common seasoning used in breakfast sausage? Germany oregano sage. Um, what is the popular type of breakfast sausage in the southern united states known for being spicy? It's actually chorizo. Uh, interesting one there for the spanish contingent. Which of the following sausages is traditionally sugar, cured and smoked? Is it cumberland sausage, summer sausage, chorizo or andouille andououille? Sadly, it's summer sausage. What is the name of the Scottish sausage made from oats and spices often eaten at breakfast and shaped in a square Haggis Lawn sausage and which breakfast sausage is known for its inclusion in a full Irish breakfast Cumberland? No, it's the Irish banger, apparently. And final question In what form is breakfast sausage typically served in American diners? Is it links, patties slices, or both links and patties Patty it is, I'm afraid, answer D, both links and patties. Okay, sorry about that, but after it's too difficult.
Speaker 3:I mean, I'm not an expert at all. I didn't know any of the answers After a very, very tough and arguably grossly unfair sausage round.
Speaker 1:John Graham is the winner.
Speaker 4:Well done, John.
Speaker 6:Congratulations, John.
Speaker 1:Yeah.
Speaker 3:I mean.
Speaker 1:John in fairness, you have just won an obviously fixed competition. Well done. I have never felt such tension, though I mean, john, in fairness, you have just won an obviously fixed competition.
Speaker 4:Well, they have never felt such tension, though I mean you can honestly feel it building. I mean, it's a shame that the people listening to this can't see John celebrating every wrong answer Tim gave. He was punching the air. You know this is a quiz on sausages and he was punching the air. It was brilliant.
Speaker 1:I know I've got to say Tim, you did better than most people. I mean, you know, I kid you not. You're clearly a very, very well-read and intelligent man.
Speaker 3:So I think in fairness a huge round of applause for.
Speaker 1:Tim.
Speaker 3:I have to say a Spanish person. I don't know, lara, did you consider chorizo as a sausage?
Speaker 2:No, no, no, that question it should, no, we shouldn't count it shouldn't count.
Speaker 3:It's not a sausage.
Speaker 1:No, it has the same form or whatever, but it's not considered a sausage it's not a team, you really got a very hard uh well spotted there and if you do feel as though we've been culturally insensitive to you, uh, regarding the, the way we refer to your meat products in one of your wherever you're living in Europe right now, on behalf of Registriar, we do apologize. So I guess all that remains is for us to give a huge Registriar thank you from everyone here in the virtual studio to our very special guest today, and that is in no particular order, a man whose sense of humor has to be big because we've just totally stitched him up. Live on there, uh, someone who has an encyclopedic knowledge of the topic, and if you want to network him, do uh get hold of him through our linkedin page, uh, so you can ask him your questions. It is the director of amir reporting at kaizen, uh, mr tim hartley.
Speaker 6:Tim, thanks so much I'm adding big, big bangers onto my email sign-off, so, but lovely to be here and yeah, always, always very happy to be here.
Speaker 1:Fantastic. Thank you, tim. And, of course, joining Tim as our other very special guest today, it is the Senior Director of Regulation at the FIA, that's, the Futures Industry Association, mr John Graham. John, thank you so much.
Speaker 5:Thank you so much. Lots of fun. Always good to be here. I noticed that Tim didn't congratulate me on winning the quiz, but we'll let that one pass. Lots of fun guys, thank you.
Speaker 1:I guess we also have to thank our virtual studio crew. We've put in a huge amount of work behind the scenes with all the market participants and all the sort of challenging issues we're facing, as well as turning up for the podcast. So, in no particular order, again, huge thanks to the pride of Spain herself, the head of institutional relations, laura Rodriguez.
Speaker 2:Thank you, andrew, and thanks a lot to Tim and John. It was great. I really enjoyed all the information, also the contest, and I have to say just to keep giving information on the culture, on the 15th of May there is this celebration in Madrid. It's San Isidro, the patron saint of Madrid, and we have a lot of concerts. People enjoy typical dances and there is like a famous dance called totis. So we will have a lot of concerts. People enjoy typical dishes and there is like a famous dance called totis, so we will have a really nice time in a few days so that you have some culture information from Madrid.
Speaker 1:And on that front as well, huge thanks to the voice of reason himself, the head of business development, the busiest man in the UK right now because John is away and that is, of course, mr nick bruce nick. Thank you so much no, thank you.
Speaker 4:Obviously a huge thank you to john and tim, and I've got to say, a fantastic episode, I think, for barbara's last. We're going to miss barbara immensely, but it's been a lot of fun.
Speaker 1:So, and thank you, barbara, for everything you've done for us yes, barbara uh ruiz alon, the nicest and most efficient person in the organization for at least the last 10 years. We are going to miss you. And, founding member of the Virtual Studio crew, been in over nearly 100 podcasts so far, which is quite a podcasting career. Barbara, what can I say other than thank you so much for everything you've done for the show and for the clients, and we'll see you when your clients side what can I say?
Speaker 3:I mean it's it's been an honor. I learned so much from the crew, from all our guests, uh. So, yeah, keep it up. You have to keep it up. This podcast is amazing. I think this actual recording uh, you know, uh feels the way uh we leave the podcast. I think it's uh the only way you can make a relatively intense topic like the reporting industry uh to be a pretty easy going listening uh. So, yeah, just thank you all. Thanks, uh, andrew, nick, laura and John Kernan as well, and of course, today to John and team, because it's been a great honor to share with you my last episode. So, thank you very much all.
Speaker 1:Okay, that's it. That is the end of another show. Now, barbara may be leaving, but we are not. We will be right back here next month with another show, with more coverage, with more in-depth analysis of the big issues that are shaping the trade repository industry, shaping the lives of market participants, data quality, you name it, we've got it, and so, from everyone here, it's a big goodbye, and do join us on our LinkedIn page if you want to connect with anyone that's been on the show this season. That is linkedincom. Slash company slash register, hyphen TR, and we would love to hear from you and, in the meantime, from me, andrew Keith Walker, and from our producer, liana Sudan. Goodbye, goodbye, it's a big goodbye from us, and we'll see you next time. Bye-bye.