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Guide & Checklist GUIDE & CHECKLIST The Depository Trust & Clearing Corporation GLOBAL TRADE REPOSITORY (GTR) BREXIT ACTIVITY GUIDE & CHECKLIST As you determine your post-Brexit reporting obligations, DTCC is committed to supporting you every step of the way whether you need reporting in EU27, UK or in both jurisdictions. In this regard, we are delighted that on Friday 1st March the European Securities and Markets Authority (ESMA) granted authorization for DTCC Data Repository (Ireland) Plc (or “DDRIE,” our EU27 trade repository) as the first new trade repository (TR) to be successfully registered by ESMA to operate within the EU27 post-Brexit. DDRIE will not be operationally activated until Brexit takes effect, i.e. 11 p.m. London time (British Summer Time) / 12 midnight Brussels time (Central Europe Summer Time) on the 12th April. Clients must therefore continue to send all ESMA reportable trades to DTCC Derivatives Repository Plc, “DDRL,” until 11 p.m. London time (British Summer Time) / 12 midnight Brussels time (Central Europe Summer Time) on the 12th April. ESMA authorization of DDRL will be withdrawn at this point and Financial Conduct Authority (FCA) authorization for DDRL to operate in the UK will come into effect. Post-Brexit, ESMA reportable trades must be reported to DDRIE, FCA reportable trades to DDRL. In the event Brexit is delayed, DDRL will remain the DTCC’s only operationally active ESMA authorized TR until further notice. The following activity guide is intended to help clients better understand the data migration processes and timelines in the weeks up to and including the Brexit weekend and effectively provides a checklist for all activities. PRE-BREXIT ACTIVITIES UK TR STAGING AREA PRE-BREXIT DDRL Saturday ACTIVITY 1 ESMA Expired ESMA Open ESMA Expired 2nd March DTCC to copy all historic EMIR data into UK TR staging area. DTCC will take a cut of all historic EMIR data as of close of business on Friday 1st March. COMPLETED ON SCHEDULE ESMA Expired FCA Open FCA Expired UK TR STAGING AREA PRE-BREXIT DDRL ACTIVITY 2 Current FCA & BoE entitlement rules are as follows: 1) Reporting Counterparty Legal Entity Identifier (LEI) has B jurisdiction DTCC to identify historic trades that FCA & Bank of England (BoE) currently Saturday 2) ID of Other Counterparty LEI has B jurisdiction (Pre-Brexit) have access to under their EMIR mandate. ) CCP ID LEI has B jurisdiction (Bank of England only) 16th March Logic to identify historic trades that FCA & BoE had access to under their mandate will ) Venue of Execution MIC has B urisdiction be based upon the current Regulator Report entitlement rules. ) Underlying ID has B jurisdiction ) Reference Entity has B LEI or populated with B UK TR STAGING AREA PRE-BREXIT DDRL ACTIVITY 3 Saturday DTCC to lter out non-applicable trades that are not identied under the FCA mandate. ESMA Open ESMA Expired 6th April DTCC will remove the trades that the FCA and BoE have never had access to under FCA Expired BoE Expired their mandate. FCA Open FCA Expired UK TR STAGING AREA PRE-BREXIT DDRL ACTIVITY 4 DTCC to copy over all historic trades that FCA & BoE currently (Pre-Brexit) have Friday access to under their EMIR mandate between 2nd March and 12th April. 12th April ESMA Open ESMA Expired This secondary historic data copy will incorporate trades expired between Friday 1st March (see Activity 1) and 12th April. FCA Open FCA Expired FCA Open FCA Expired Any live trade captured by the entitlement rules outlined under Activity 2 will be closed during the migration. Note only open B domiciled trades will be left open within the UK TR. Securing Today. Shaping Tomorrow.® BREXIT WEEKEND ACTIVITIES BREXIT WEEKEND ACTIVITIES DDRL DDRIE Friday 12th April ACTIVITY 5 11 p.m. London time DTCC run EoD processes for close of business on the Friday 12th April. ESMA Open ESMA Expired (British Summer Time) / • DTCC will run its standard End of Day processes on Friday 12th April. 12 midnight Brussels time • DTCC will run its standard EoD reporting process. Empty TR (Central Europe Summer FCA Open FCA Expired Time) • Clients reporting throughout Friday should take place as usual. DDRL DDRIE ACTIVITY 6 DTCC re-label DDRL database from DDRL to DDRIE. ESMA Open ESMA Expired No client action. Empty TR HARD BREXIT FCA Open FCA Expired Saturday 13th April ACTIVITY 7 DTCC copy of UK trades (domicile of LEI) from DDRIE to DDRL. ESMA Open ESMA Expired • UK trades are identied via domicile of LEI. FCA Open FCA Expired Sunday FCA Open FCA Expired 14th April • UK trades are copied from EU TR/DDRIE and UK TR/DDRL. • No client action. ACTIVITY 8 ESMA Open ESMA Expired DTCC terminate UK trades (domicile of LEI) from DDRIE. FCA Open FCA/BoE Expired FCA EXPIRED UP TO 12TH APRIL • UK trades are identied via domicile of LEI. • Open UK trades are agged/suppressed/terminated from EU TR/DDRIE. FCA Open Monday DDRL DDRIE 15th April ACTIVITY 9 6 a.m. London time Generate regulator and client reports from EU TR and UK TR. UK ESMA/NCAs EU27 (British Summer Time) / 7 a.m. Brussels time • UK TR reports will reect copied UK trades. FCA/BoE Reports Counterparties Counterparties Counterparties (Central Europe • DTCC will run its standard EoD reporting process. Reports Summer Time) Reports Reports HARD BREXIT WEEKEND TIMINGS Please note that these timings are indicative only and will be subject to change. UK TR EMIR REPORTS EMIR AND FCA INGESTION WITH UK LONDON TIME DATA MIGRATION UK TRADE EMIR REPORTS GTR REPORT ALL CLIENTAND UK/FCA INGESTION UK GO LIVE AND EU TR INGESTION UNAVAILABLE TRADES UK TR REPORT DATE (British Summer AND VALIDATIONS TERMINATION WITHOUT UK MAINTENANCE INTERNAL REGULATOR SANITY CHECK UK TR DOWN (QUEUED) (DEPENDENT ON INCLUDED GENERATION Time) (DTCC INTERNAL) FROM EU TR TRADES WINDOW VALIDATIONS REPORTS (DTCC INTERNAL) INGESTION IS SUBMISSION RUN 1 RUN 2 (BAU) (DTCC INTERNAL) RELEASED OPEN METHOD) (BAU) 12 AM 1 AM 3 AM 4 AM 1AM - 9AM 6 AM Saturday 99 AM 13th 10 AM 12AM - 11PM 10AM - 12PM April 12 PM 6AM - 9PM 2 PM 5 PM 12AM - 5PM 2PM - 9PM 7 PM 9 PM 7PM - 1AM 11 PM 1 AM 3 AM 5 AM 3AM - 12PM 3AM - 12PM Sunday 6 AM 14th 12 PM April 4 PM 12PM - 5PM 12PM - 5PM 5 PM 9 PM 10 PM 9PM - 1AM Monday 1 AM 15th April FCA LIVE Securing Today. Shaping Tomorrow.® BREXIT CHECKLIST DETERMINE POST-BREXIT REPORTING OBLIGATION COMPLETE DOCUSIGN TO ONBOARD TO DDRIE TERMINATE DDRL ACCOUNT (IF APPLICABLE) ENSURE ALL RELEVANT LEIS ARE ONBOARDED SET UP SFTP AUTOROUTE REPORTS CHECK DELEGATED REPORTING PARTNERS ARE AWARE OF YOUR REQUIREMENTS ENSURE THIRD PARTY VENDORS ARE ALIGNED TO PLANS DOWNLOAD PRE-BREXIT BILLING SUBSTANTIATION REPORTS DOWNLOAD PRE-BREXIT TRADE STATE REPORTS TO LEARN MORE VISIT DTCC.COM/BREXIT OR CONTACT US AT [email protected] The content, information and any materials provided by The Depository Trust and Clearing Corporation (“DTCC”) and/or its affiliated companies or subsidiaries in this document is provided on an “as is” basis and for informational purposes only and does not constitute a recommendation, offer or invitation to engage in any investment or other financial activity. DTCC disclaims all warranties, expressed or implied, as to the accuracy of any data provided, including, without limitation, liability for quality, performance and fitness for a particular purpose arising out of the use of the data. DTCC shall not have any liability, duty or obligation for or relating to the data contained herein, any errors, inaccuracies, omissions or delays in the data, or for any actions taken in reliance thereon. Any unauthorized use, including but not limited to copying, distributing, transmitting or otherwise of any data appearing herein without written consent is not permitted and may violate the proprietary and intellectual property rights of DTCC under applicable intellectual property laws and associated regulations and statutes. Copyright © 2019 The Depository Trust & Clearing Corporation. All rights reserved. Securing Today. Shaping Tomorrow.®.
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