Comparison to Selected Canadian Provinces: Ontario, Manitoba and Quebec Derivatives Data Reporting Requirements to the Derivatives Data Reporting Requirements of the European Union (European Market Infrastructure Regulation “EMIR”) and United States (Dodd-Frank Act implemented through the CFTC’s Derivatives/ Swap Data Reporting Regimes

Requirement Jurisdiction CFTC Rule implementing EMIR (EU) Ontario Quebec Manitoba the Dodd-Frank Act

Common to All Derivatives (or in the US Swaps) 1 Individual swap identifier Yes - A Unique Swap Yes – Unique Trade ID, Yes – a unique Yes – a unique Yes – a unique Identifier (“USI”) as transaction identifier transaction identifier transaction identifier provided for under § 45.5 of the CFTC’s Regulations 2 Individual entity identifier of the reporting Yes - a Legal Entity Yes – requires a unique Yes - LEI Yes - LEI Yes - LEI counterparty Identifier (“LEI”) of the code, a client code in the Reporting Counterparty case of an individual. as mentioned under § Must include the name of 45.6. If the CFTC has not the reporting counterparty assigned one then the if the counterparty ID internal repository does not contain it identifier is used. 3 Corporate sector of the reporting counterparty No Yes – Ex. bank, No No No insurance company 4 Indication of whether the reporting counterparty Yes No Yes – indicate whether Yes – indicate whether Yes – indicate whether is a swap dealer in the US and a derivatives the reporting counterparty the reporting counterparty the reporting counterparty dealer in the selected Canadian provinces with is a derivatives dealer is a derivatives dealer is a derivatives dealer respect to the swap or the derivative 5 Indication of whether the reporting counterparty Yes No No No No is a major swap participant with respect to the swap 6 If the reporting counterparty is not a swap dealer Yes – financial entity as Yes – in accordance with No No No or a major swap participant with respect to the defined in CEA § points 8 and 9 of Article 2 swap, an indication of whether the reporting 2(h)(7)(C) of EMIR counterparty is a financial entity in the US or a financial counterparty in the EU 7 An indication of whether the reporting Yes – a U.S. person Yes – need the full No No No counterparty is a domestic person address 8 Indication the swap will be allocated Yes No No No No 9 Broker ID No Yes – If a broker acts as Yes – LEI of a broker who Yes – LEI of a broker who Yes – LEI of a broker who an intermediary without is not a counterparty is not a counterparty is not a counterparty becoming a counterparty 10 Reporting entity ID No Yes – if the reporting Yes Yes Yes counterparty has delegated submission of the report to a third party

11 Clearing member ID No Yes – in the case a Yes - LEI of the clearing Yes - LEI of the clearing Yes - LEI of the clearing reporting counterparty is member if they are not a member if they are not a member if they are not a not a clearing member counterparty counterparty counterparty 12 Beneficiary ID No Yes – the party subject to No No No the rights and obligations arising from the contract. If an entity with many beneficiaries (like a trust) then indicate the type of entity. 13 Trading capacity of reporting counterparty No Yes – is the reporting No No No counterparty a principal using their own account or an agent 14 Counterparty side No Yes – identifies whether Yes – indicates if the Yes – indicates if the Yes – indicates if the the contract was buy or reporting counterparty reporting counterparty reporting counterparty sell was the buyer or seller was the buyer or seller was the buyer or seller 15 Directly linked to commercial activity or treasury No Yes – as referred to in No No No financing Article 10(3) of EMIR 16 If the swap will be allocated, or is a post- Yes the LEI, same No No No No allocation swap, the Individual Entity Identifier of procedure as LEI the agent requirements for a reporting counterparty 17 An indication that the swap is a post-allocation Yes No No No No swap 18 If the swap is a post-allocation swap, the Yes – the USI as No No No No individual swap identifier of the original provided in § 45.5 transaction between the reporting counterparty and the agent 19 The Individual Entity Identifier of the non- Yes – the LEI as provided Yes Yes – LEI Yes – LEI Yes – LEI reporting counterparty in § 45.6 20 If there is no regulator approved Individual Entity Yes – if the repository No No No No Identifier for the non-reporting counterparty, then does not yet have an the internal identifier of the repository identifier for the non- reporting counterparty then the space is left blank and filled in once the repository assigns an identifier 21 Indication of whether the non-reporting Yes No No No No counterparty is a swap dealer with respect to the swap 22 Indication of whether the non-reporting Yes No No No No counterparty is a major swap participant with respect to the swap

23 If the non-reporting counterparty is not a swap Yes – as defined in US No No No No dealer or a major swap participant with respect Commodity Exchange Act to the swap, an indication of whether the non- § 2(h)(7)(C) reporting counterparty is a financial counterparty 24 An indication of whether the non-reporting Yes – a U.S. person Yes – is the other Yes - indicate if they are Yes - indicate if they are Yes - indicate if they are counterparty is a domestic person counterparty domiciled a local counterparty a local counterparty a local counterparty outside European Economic Area. 25 A product identifier assigned to the swap Yes – a Unique Product Yes Yes Yes Yes Identifier (“UPI”) as under § 45.7 26 If no product identifier because the swap is not Yes – pursuant to the No No No No sufficiently standardized a taxonomic description CFTC approved product of the swap classification system 27 If no product identifier because it has not been Yes – either in the form of No No No No created yet, then the repository description the repository’s internal identifier or description 28 An indication that the swap is a multi-asset swap Yes - Field values: Yes, No No No No Not applicable 29 For a multi-asset swap, an indication of the Yes - Generally, the asset Yes – the underlying Yes Yes Yes primary asset class class traded by the desk trading the swap for the reporting counterparty. Field values: credit, equity, FX, rates, other commodity 30 For a multi-asset swap, an indication of the Yes - Field values: credit, No Yes Yes Yes secondary asset class equity, FX, rates, other commodity 31 Indication the swap is a mixed swap Yes – Field values: Yes, No No No No Not applicable 32 For a mixed swap reported to two non-dually Yes No No No No registered swap data repositories, the identity of the other swap data repository to which the swap is or will be reported 33 Contract type Yes - Ex. swap, forward, No Yes Yes Yes option, vanilla option etc. 34 Block trade indicator Yes – indicate whether or No No No No not a swap qualifies as a block trade or large notional swap, enter N/A until the CFTC determines the appropriate minimum block size

35 Clearing threshold No Yes – is the reporting No No No counterparty above the clearing threshold as in Article 10(2) of EMIR 36 Action No No Yes – Ex. new Yes – Ex. new Yes – Ex. new transaction, modification, transaction, modification, transaction, modification, cancellation cancellation cancellation 37 Execution time stamp Yes – using Coordinated Yes Yes – using UCT Yes – using UCT Yes – using UCT Universal Time (“UCT”) 38 Execution venue Yes - The facility or Yes No No No designated contract market on or pursuant to the rules of which a swap was executed. Field values: Identifier or name of venue or “off-facility” if not so executed. 39 Start date Yes – date the swap goes Yes Yes Yes Yes into effect, not necessary for foreign exchange transactions 40 Maturity, termination or end date Yes – the date on which Yes, if maturity, Yes Yes Yes the swap expires or termination, or settlement settles date are different they shall be reported separately 41 Timestamp for submission to swap data Yes – submitted in using Yes – and an indication of Yes – using UTC Yes – using UTC Yes – using UTC repository UCT and recorded manual or electronic automatically wherever confirmation possible 42 Clearing indicator Yes – a yes/no indication Yes – signifies if there is No No No of whether the swaps will an clearing obligation be cleared by a under Regulation (EU) derivatives clearing 648/2012 organization 43 Clearing vendor Yes – identifier or name Yes – unique code for the Yes – LEI required of the Yes – LEI required of the Yes – LEI required of the of derivatives clearing CCP that has cleared the clearing agency clearing agency clearing agency organization contract 44 Cleared No Yes – indicates if the Yes Yes Yes swap has been cleared 45 Clearing timestamp No Yes – time and date of Yes in UTC Yes in UTC Yes in UTC clearing

46 Intragroup No Yes – indicates if the Yes – inter-affiliate Yes – inter-affiliate Yes – inter-affiliate swap was entered into as transaction indicator transaction indicator transaction indicator an intragroup transaction as per Article 3 of Regulation (EU) 648/2012 47 If the swap will not be cleared an indication of Yes – an indication if the No Yes Yes Yes exception election. exception under CEA § 2(h)(7) 48 Identity of the counterparty electing the Yes - Field values: LEI or No No No No exception substitute identifier as above 49 Indication of collateralization Yes - Is the swap Yes – must also include Yes – Field values: Fully, Yes – Field values: Fully, Yes – Field values: Fully, collateralized? And if so whether collateralization partially, one-way, partially, one-way, partially, one-way, to what extent? Field was performed on a uncollateralized. uncollateralized. uncollateralized. values: Uncollateralized, portfolio basis netted out partially collateralized, v. per trade (if so the one-way collateralized, code for the portfolio) and fully collateralized the value of collateral posted 50 Any other term(s) of the swap matched or Yes - Ex. early Yes No No No affirmed by the counterparties in verifying the termination option clause, swap use as many fields as necessary to report such term(s) 51 Mark to market value of contract No Yes Yes Yes Yes 52 Currency of mark to market value of contract No Yes No No No 53 Valuation date of last mark to market or mark to No Yes Yes Yes Yes model valuation 54 Valuation time of last mark to market or mark to No Yes No No No model valuation 55 Valuation type, mark to market or mark to model No Yes Yes Yes Yes valuation 56 Compression No Yes – identify if contract Yes – identify if contract Yes – identify if contract Yes – identify if contract results from a results from a results from a results from a compression exercise compression exercise or compression exercise or compression exercise or reconciliation exercise as reconciliation exercise as reconciliation exercise as well well well 57 Quantity of contracts included in the report No Yes No No No 58 Master agreement type – Ex. ISDA No Yes Yes Yes Yes 59 Master agreement version No Yes Yes Yes Yes 60 Deliverable currency No Yes Yes – settlement Yes – settlement Yes – settlement currency currency currency 61 Electronic trading venue identifier No No Yes – LEI or, if not Yes – LEI or, if not Yes – LEI or, if not available, the name of the available, the name of the available, the name of the venue venue venue

62 Asset class No No Yes - major class of Yes - major class of Yes - major class of product Ex. interest rate, product Ex. interest rate, product Ex. interest rate, credit credit credit 63 Embedded option No No Yes – indicate yes or no Yes – indicate yes or no Yes – indicate yes or no

Credit and Equity Swaps 64 Indication of the counterparty purchasing Yes – Field values: LEI or No No No No protection substitute identifier as above 65 Indication of the counterparty selling protection Yes – Field values: LEI or No No No No substitute identifier as above 66 Information identifying the reference entity Yes - The entity that is No No No No the subject of the protection being sought by the swap. Field values: LEI, substitute identifier, or name 67 Price Yes – Ex. strike price Yes – excluding Yes Yes Yes commission and interest 68 Notional amount and currency in which it is Yes Yes Yes Yes Yes expressed 69 Amount and currency of any upfront payments Yes Yes Yes – and its currency Yes – and its currency Yes – and its currency 70 Payment frequency of the reporting counterparty Yes – description of the Yes Yes Yes Yes payment stream 71 Payment frequency of the non-reporting Yes - description of the Yes Yes Yes Yes counterparty payment stream

Foreign Exchange Transactions 72 Currency 1 Yes – ISO code Yes Yes Yes Yes 73 Currency 2 Yes – ISO code Yes Yes Yes Yes 74 Notional amount 1 Yes – For currency 1 Yes Yes Yes Yes 75 Notional amount 2 Yes – For currency 2 Yes Yes Yes Yes 76 Exchange rate Yes - Contractual rate of Yes Yes - Contractual rate of Yes - Contractual rate of Yes - Contractual rate of exchange of the exchange of the exchange of the exchange of the currencies currencies currencies currencies 77 Delivery type Yes - Physical Yes Yes – cash or physical Yes – cash or physical Yes – cash or physical (deliverable) or cash (non-deliverable) 78 Cross currency if different from delivery currency No Yes No No No 79 Forward exchange rate on value date No Yes No No No 80 Exchange rate basis – quote base for exchange No Yes No No No rate

Interest Rate Swaps 81 Day count convention Yes No Yes Yes Yes

82 Notional amount (leg 1) Yes – the current active Yes Yes Yes Yes notional amount 83 Notional currency (leg 1) Yes – ISO code Yes Yes Yes Yes 84 Notional amount (leg 2) Yes – the current active Yes Yes Yes Yes notional amount 85 Notional currency (leg 2) Yes – ISO code Yes Yes Yes Yes 86 Payer (fixed rate) Yes – is the reporting No No No No party a fixed rate payer? Yes/No/Not applicable 87 Payer (floating rate leg 1) Yes - If two floating legs No No No No the payer for leg 1 88 Payer (floating rate leg 2) Yes - If two floating legs No No No No the payer for leg 2 89 Direction Yes – for swaps it is No No No No whether the principal is paying or receiving the fixed rate. Float-to-float and Fixed-to-fixed indicate N/A. For non- swap instruments indicate the instrument that was bought or sold. 90 Option type Yes – Ex. put, call Yes Yes Yes Yes 91 Fixed rate Yes Yes – and of leg 1 and Yes – and of leg 1 and Yes – and of leg 1 and Yes – and of leg 1 and leg 2 if applicable leg 2 if applicable leg 2 if applicable leg 2 if applicable 92 Fixed rate day count fraction Yes – Ex. actual 360 Yes Yes Yes Yes 93 Fixed leg payment frequency No Yes Yes Yes Yes 94 Floating rate payment frequency Yes Yes Yes Yes Yes 95 Floating rate reset frequency Yes Yes Yes Yes Yes 96 Floating rate index name/rate period Yes – Ex. USD-Libor- Yes - and of leg 1 and Yes - and of leg 1 and Yes - and of leg 1 and Yes - and of leg 1 and BBA leg 2 if applicable leg 2 if applicable leg 2 if applicable leg 2 if applicable

Other Commodity Swaps 97 Buyer – the counterparty purchasing the product Yes - Field values: LEI or No No No No substitute identifier as above 98 Seller – the counterparty offering the product Yes - Field values: LEI or No No No No substitute identifier as above 99 Sub-asset class – specific information No No Yes – Ex. Agriculture Yes – Ex. Agriculture Yes – Ex. Agriculture 100 Quantity unit of measure Yes - Ex. barrels, tons Yes Yes Yes Yes 101 Quantity of commodity quoted on swap Yes Yes Yes Yes Yes 102 Quantity frequency, the rate at which the Yes – Ex. hourly, weekly Yes Yes Yes Yes quantity is quoted on the swap 103 Total quantity for the entire term of swap Yes Yes Yes Yes Yes 104 Settlement method Yes – Cash or physical Yes – including delivery Yes – cash or physical as Yes – cash or physical as Yes – cash or physical as

points and well as location and well as location and well as location and interconnection points connection points for connection points for connection points for and delivery start and end physical delivery physical delivery physical delivery dates 105 Price Yes Yes – excluding Yes Yes Yes commission and interest 106 Price unit - Unit of measure applicable to the Yes Yes Yes Yes Yes price of the swap 107 Price currency Yes – ISO code No Yes Yes Yes 108 Buyer pay index Yes No No No No 109 Buyer pay averaging method Yes No No No No 110 Seller pay index Yes No No No No 111 Seller pay averaging method Yes No No No No 112 Grade of commodity if applicable Yes Yes Yes Yes Yes 113 Option type Yes – Ex. put, call Yes Yes Yes Yes 114 Option style Yes – Ex. American, Yes Yes Yes Yes European 115 Option premium Yes Yes Yes Yes Yes 116 Hours from through Yes – for electric power, Yes Yes Yes Yes the hours of the day the swap is effective 117 Hours from through time zone Yes – for electric power, Yes Yes Yes Yes the prevailing time zone 118 Days of week Yes – for electric power, Yes Yes Yes Yes profile applicable for the delivery of electric power 119 Load type Yes – for electric power, Yes Yes Yes Yes the load profile