SFTR DELEGATED REPORTING OVERSIGHT
INTENSIVE PROGRAMME
SITUATION APPRAISAL
From 11 October 2020, UCITS ManCos and AIFMs that are counterparties to Securities Financing Transactions are required to report details of those SFTs to a Trade Repository. ManCos can appoint a delegate to carry out SFTR reporting on their behalf. However, ManCos remain responsible for compliance with their SFTR reporting obligations and the Central Bank of Ireland expects them to closely oversee their SFTR reporting delegate.
ManCos need to understand the background and purpose of SFTR generally and their reporting obligations specifically. Armed with that knowledge, they need to design and implement an oversight framework including a SFTR reporting policy and written agreement with the SFTR reporting delegate.
SFTR DELEGATED REPORTING OVERSIGHT - INTENSIVE PROGRAMME
Objectives, Measures of Success & Value
Objectives:
A rapid deep-dive programme to assist ManCos in designing and implementing an effective and appropriate SFTR reporting oversight framework taking into account:
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The Central Bank’s expectations regarding how reporting delegates are overseen; and
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How peer ManCos are approaching this task.
#SFTRReporting
Measures of Success:
ManCos will leave the Intensive Programme with:
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Knowledge of the background and purpose of SFTR generally and their reporting obligations specifically.
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A practical understanding of their reporting obligations under SFTR and of the Central Bank’s expectations regarding how ManCos should oversee their reporting delegate on a day-to-day basis.
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A framework for constructing the firm’s reporting delegate oversight programme.
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Template reporting delegate oversight policy and template written agreement with a reporting delegate.
#SFTRReporting
Value:
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Minimise the risk of reputational damage and costly regulatory fines for breaching SFTR regulatory obligations.
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Design and build an SFTR delegated reporting oversight framework that complies with regulatory requirements, Central Bank expectations and best practice.
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Avoid the time and expense of trying to fix problems after the event. Get your oversight right from the outset.
#SFTRReporting
MEET YOUR FACILITATOR
This programme is delivered by Daniel Lawlor, Lead Advisor at Aquest. Daniel is the former Head of Funds Policy Team at the Central Bank of Ireland and, before that, Funds Lawyer at William Fry. He has 17 years’ experience in the financial services industry which was gained both from as a funds lawyer and financial regulator.
METHODOLOGY
PHASE 1
Setting us up for success
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Client take-on process to include review of current SFTR usage, current proposals in relation to delegation of SFTR reporting including proposed SFTR reporting delegate and proposed Trade Repository and up to 7 bios for management team
#SFTRReporting
PHASE 2
‘Lay of the land’ workshop
Interactive Workshop where:
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background and purpose of SFTR generally and SFTR reporting obligations specifically, including Central Bank expectations, are explained by the Facilitator; and
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specific approach to be adopted by the ManCo is discussed and tested between ManCo’s SFTR Delegate Reporting Oversight Team and Facilitator
#SFTRReporting
PHASE 3
Full Analysis of your Submission
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Rapid response access to Daniel Lawlor for 1 ManCo contact for 5 consecutive business days following the Interactive Workshop to address any follow up queries ManCo may have.
#SFTRReporting