Consultation Paper: Standard Regarding Position Transfers

1. EMIR Refit Prior UTI

The FIA Reporting call which is tracking open issues/challenges in the industry as a result of EMIR Refit (and/or any other regulatory changes). One of the issues the industry has been raising since EMIR Refit is around position transfers and the need to report the Prior UTI. This is not typically available to the party accepting the Position transfer, so there is a need to have a workflow in place to communicate and capture the UTI between the two parties to the transfer. All CCP’s should include the Prior UTI as a populated field in the position transfer process so it can be consumed by the Clearing member (s) for EMIR Refit reporting obligations. There should be a connection between the 2 FIA WG’s to ensure this requirement is understood and covered by the Standard.

2. CCP API’s

From a Vendor perspective having API connectivity to send / consume position transfers would be beneficial to remove manual processes / uploads. The API’s should be consistent across all the CCP’s which will allow a standardised connectivity and not a bespoke set up per CCP. The API will also greatly improve the time taken to instruct and complete the transfer process.

3. Impediments

Adoption of the ‘Standard’ by the CCP’s and timeframe to implement i.e. clients may send all CCP data in the new proposed Standard but not all CCP’s may be ready to accept this and this will lead to manual work to be performed on the transfer files for CCP’s who have not adopted the standard.
Ability of the end clients to meet the deadlines for the 3 Transfer Types (Simple, Complex, Complex Exchange Approval). Tracking and adherence of CM’s / end clients to the timeframes stipulated for the position transfer types.

4. DMIST Standard Cleared Swap Positions

Yes, this should be aligned as closely as possible to the Derivatives standard as end clients will potentially hold positions in both asset classes so alignment would be beneficial where appropriate.