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We discuss with Regulation Asia on how firms can better prepare for the upcoming regulatory landscape.
Speaker 1 [00:00:04] So 21 is relatively new. Right. It's it's it's something that's kind of only really been established or been presented to the market in the last six months or so. It's it's an S.E.C. regulation and it's to do with securities lending. So we already have securities lending regulation by ESMA for SFR, which was came into force a couple of years ago dealing with securities lending repos, stock bar, etc., etc.. It's an end of day regime and a very sorry obligation looking at all that data kind of broadly aligned with G20, but not not obviously not at sea. Now 20 dash one is a similar beast, but for US markets currently anything you do on us is not relevant to Europe for ESMA. So this is a broadly similar regulation. It has some differences. It's not as complicated with a number of fields, but it also has some interesting points around it. It's single sided. Unlike SFR, it again, it's the first time that it's the first time that the US markets will have to get this data and present it to a regulator. In this format, at least the single sided nature of it is is very different to what most of G20 is in fact, or the US regimes tend to be. So North American regimes are only one party reports as opposed to both sides, so that that kind of reconciliation between the two parties is less important. But it also adds complexity in that, you know, you have to report your opponents, your counterparties data and make sure you have all that data in a considered fashion. So there's no control points around that. But what's also interesting is that it has a very tight SLA. So there are essentially three parts to Kensi dash one. One is the transactional data, which has to be done within 15 minutes. And there's a couple of end of day points around volumes and other things which we shall there's more detail about that necessary. But that 15 minute SLA is challenging because the regulations say that's from the point of booking. Okay. Which is very similar to the SLA as you have on CFTC. So the moment that it's booked, essentially captured, you have the clock starts ticking until you have to get it to the regulator. Now, however, the industry considers booking to be at the point of settlement under the as your agreement with MSL. So there's already a discrepancy between when the industry thinks they're ready to kind of populate that data or publish that data and when the regulator wants it. So that's going to be a challenge. How is that going to work? Does that mean there's differences in booking models? When do you when do you have the veracity of those points? If you don't have them in 15 minutes, what are you going to do? So there's there's already debate and consultation about what those delays mean. Another very interesting point about Tennessee Dash one is that they have different UTR requirements, so utilize unique transaction identifier. It's a it's a global standard that is actually being harmonized and even more standardized. By keeping my ASCO and technical standards published about who generates this, how you get this information, how you share it. But for tenancy dash one, that's still has to be generated by FINRA and they have different criteria to what SFR does. So if you are in a situation where for SFR, you have a, you know, a bilateral agreement to say party A will always generate duties when we are trading. That may not be how FINRA said so when you have a global standard which immediately is in does not correlate with a tenancy, that's one standard. Again, there's questions about that. How is that going to work? Will we need separate bilateral agreements to be able to handle that, that difference from the global standard that that's forthcoming?
Speaker 1 [00:00:03] One of the benefits of of how? How we do our reporting products. We have a broad, which is that it's a community of users. So we have you know, we have well over 20 customers in G20 alone, as well as many more outside of of those regulations. But we very much operate as a community of knowledge. There's a mutualization benefit that comes from being part of this community. So when we look at rank change, you know, how does that what's that look like for us? It's tends to start obviously with our SMEs and our analysts looking at what that change means. And then we run working groups with our with our community groups to look at all that information and they feed back to us and we feed back to them. So we have we already have a mutualization of interpretation. And similarly, you know, post that interpretation, we have a mutualization of benefit. So if if a customer has requirements or product enhancements, that will propagate through to all of our community. So we in a fortunate place that we can we can take best practice from any number of firms who are part of that community and bring it all to the fore to enable the most efficient and most, you know, complete reporting that we can do. Now, it's you know, there were other you know, one of the natural benefits of that is if we look at what we do as far as our usability and we've talked about we've talked about flexibility with regard to how how you can switch in and switch out connectors and what the harmonization model of Pair X brings to that. And we talked a little bit now about community and how, you know, having a holistic approach across a number of of different customers allows us to kind of drive best practice within how we report. But there's also there's also kind of operability as well. So what does that mean as far as how do how can we make our software more flexible to the actual user? So if we if I go way back at the beginning when we talked about was an emissions for CFTC rewrite where you have the seven business day perspective to be able to to fix all of your all of your exceptions. So we've worked very hard with our community to kind of look at what that operational model looks like from all the different firms and how can we best represent that within our dashboard, within our user interface. So when we build that towards a kind of day in the life process, where what does a user need to do on a certain what's the first thing they're going to do in the day? They need to check their acceptance. So how do we bring those to the force that we've designed? You know, we have an exception matrix which is specific to can be subdivided slice and dice across all of the machines you have, which brings all those important those first most primary items you need to deal with right at the front of the dashboard.
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