Trade Repository: Get All the Details
Based on the Financial Market Infrastructure Act (FMIA; in German ‘Finanzinfrastrukturgesetz’ FinfraG), all companies with a registered office in Switzerland are obliged to report derivative transactions to an authorized trade repository. In response to client demand, SIX has launched a central trade repository for the reporting of OTC and exchange traded derivative (ETD) transactions under FMIA.
Counterparties will have to start reporting open OTC transactions on 1 October 2017 (CCP or FC+), 1 January 2018 (FC- or NFC) or 1 January 2019 (other constellations) depending on their FMIA classification.
This info center provides information on client reporting, registration, regulator access as well as statistics.
This section provides documents outlining key information on registration, onboarding as well as technical documents – everything you need to know about SIX Trade Repository.
Can't find the information you need? Please contact us.
Counterparties which need to report
A counterparty's obligation to report depends on its classification. Counterparties are allowed to delegate their reporting duties to the other counterparty or to third parties. Nevertheless, even when delegated to a party already reporting transactions under EMIR, FMIA reporting duties are only fulfilled if reported data corresponds to FMIA requirements (not EMIR) and data is reported to a FINMA approved Trade Repository. FMIA differentiates between four counterparty classes including FC (+/-) and NFC (+/-), see definitions below:
Financial Counterparties (FC)
- Large Financial Counterparties (FC+) for example are banks, securities dealers, asset managers, fund management companies.
- Small Financial Counterparties (FC-) are FCs below an aggregated threshold of CHF 8 billion of open OTC derivative contracts on a 30-working-day rolling.
Non-Financial Counterparties (NFC)
- Non-Financial Counterparties (NFC) are undertakings which are not an FC+ or FC- with an entry in the Swiss register of commerce.
- Small Non-Financial Counterparties (NFC-) are NFCs below certain thresholds of open OTC derivative contracts on a 30-working-day rolling basis:
- CHF 1.1 billion for credit and equity derivatives and
- CHF 3.3 billion for interest rate, FX, commodity and other derivatives (hedging transactions excluded)
Legislative Requirements – Timeline
SIX Trade Repository Ltd is compliant with FMIA regulation and is strictly designed according to their regulatory requirements. You can find the listed legal documents which form the foundation of our technical solution and offering on the FMIA website.
Requirements
- From 01 October 2017
Start reporting FC+ - From 01 January 2018
Start reporting FC-/NFC+ - From 01 January 2028
Start reporting NFC-
Register Now
The onboarding process is in progress. In order to get started, please complete the onboarding application (select your option) and send it to our onboarding desk traderep@six-securities-services.com. If there are any questions please do not hesitate to contact us.
Related Documents
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Reporting Rule Book
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Price List
Once registered, these are the steps to getting started. When you are set up in our SIX Trade Repository system, you will need to install a browser certificate required by users for authentication purposes.
Getting Started
- Onboarding documentation, system functionality & demo available from SIX Trade Repository Sales/Product Management for you to discover our service offering in detail.
- Fill in our application form as a reporting user and send it to traderep@six-securities-services.com.
- Our team will set up your access to the SIX Trade Repository GUI (2 days) & FTP Gateway (within 10 days).
- You can test the user interface and technical setup in detail.
- Based on your requirements, a number of modifications are possible.
- Set up will be transferred into production.
- Report your derivative transactions under FMIA. Need assistance? Our Client Service Team will be there to help you.
SIX Trade Repository is built on a leading solution provided by UnaVista. The following technical documents provide detailed information to help support you with operational requirements and workflows.
Reportable Content under FMIA Regulation
The reporting field specifications document explains what data must be reported depending to the trade type. The sample upload files further illustrate how several trades are reported correctly according to FMIA regulation.
Reporting of Workflows and Position Changes
Besides the reporting of new trades, FMIA regulation specifies requirements regarding the trade workflows as well as position management. The following documents will provide the necessary information.
Related Documents
Direct Reporting
Direct Reporting is our Standard Reporting model which applies for clients who report their own transactions to SIX Trade Repository to satisfy their own reporting obligation under Art. 104 FMIA. This may be on behalf of one LEI (Legal Entity Identifier) or on behalf of a number of LEIs depending on the firm’s legal structure. Clients will be charged with a monthly fixed usage fee and a monthly variable volume fee depending on the volume reported.
If, in addition to their own, clients report transactions of third parties, the Delegated Reporting model and the associated fees also apply.
For further information about our price models, please see our SIX TR Price List.
Delegated Reporting
Delegated Reporting applies, if a client reports the transactions of a third party to SIX Trade Repository on behalf of this third party to satisfy the reporting obligation of said third party under Art. 104 FMIA. The third party can get a ‘read only’ view of the data within SIX Trade Repository, allowing them to see the transactions reported on their behalf. If the submitting party reports trades on behalf of third parties, the submitting party is charged CHF 350.00 per month plus an additional LEI maintenance Fee of CHF 2.50 per LEI. If the submitting party already reports its own trades to SIX Trade Repository as a reporting user, the monthly fee of CHF 350.00 is not charged.
For further information about our price models, please see our SIX TR Price List.
SIX Trade Repository provides access to the data contained in its trade repository to authorized domestic regulators in accordance with article 77 of FMIA and article 62 of FinfraV. The data will be made available from 1, October 2017 after the first reporting deadline, by email.
SIX Trade Repository publishes aggregated public statistics on a weekly basis.
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Onboarding
Yes, SIX provides a test environment identical to the production environment. By filling out the official application form for reporting users, you will automatically be set up in the test environment.
Pricing
All details to the SIX Trade Repository Tariff are officially published on our website here.
Your organization can benefit from a volume discount if all reporting firms belong to the same client group (consolidated entities within a group structure). Each client group will benefit from the same volume rebate as defined in the SIX Trade Repository Price List.
A change of fee structures would impact all clients. New fees would take effect at the beginning of the following month. The yearly agreement of the client is immaterial in this instance.
Regulatory
Yes, every reporting firm is required to have an active LEI to successfully report transactions to SIX.
Service providers can report with their LEI (during testing).
No, both regulations differentiate between certain types of counterparty classes. Due to the fact that FMIA differentiates between small and large financial counterparties and EMIR does not, all clients are requested to classify themselves under the FMIA classification as FC+, FC- (financial counterparties) NFC+ and NFC- (non-financial counterparties).
If a group’s aggregated average notional amount of open OTC derivative contracts on a 30-working-day rolling position is above CHF 8 billion, it is classified as FC+. Physically settled FX forwards and FX swaps are not taken into the threshold calculation. The threshold determination is independent of the systemic relevance of the banking group.
A company is considered an NFC+ if its aggregated rolling average position over 30 working days (including positions of any other NFCs within its group, but excluding hedging contracts) exceeds the threshold in respect of at least one of the following assset classes:
- Credit derivatives: CHF 1.1bn
- Equity derivatives: CHF 1.1bn
- Interest rate derivatives: CHF 3.3bn
- FX derivatives: CHF 3.3bn
- Commodity and other derivatives: CHF 3.3bn
Physically settled FX forwards and FX swaps are not taken into the threshold calculation. If the threshold is exceeded in at least one of these asset classes, the obligations will apply on all derivatives traded by the company, including those entered into for hedging purposes.
Clients with headquarters outside Switzerland might be subject to additional local derivatives regulations, e.g. clients with a headquarters in the EEA fall within the scope of the EU-Regulations EMIR (European Market Infrastructure Regulation). These Clients need to adhere to both regulations when trading with derivatives (Duties within the scope of FMIA as well as within the scope of their own regulation).
Yes, EMIR requires dual-sided reporting. Therefore, clients established in the EEA and within the scope of EMIR are required to report their trades to a trade repository.
EEA clients can delegate their reporting obligation to the Bank. In this case, the bank submits the transaction, position, valuation and collateral reports required under EMIR on behalf of the client, but the liability for the correctness of the data remains with the client.
Lifecycle
The regulator requires that modifications to trades are reported to the trade repository envisaging a log of events against trades. Detailed advice on what that entails is still awaited.
Reporting
Swaps consist of an FX spot trade (near leg) and an FX forward trade (far leg). The future trade has to be reported. This depends on what core banking system the client is using. If the back-office-system does not reflect two legs but only the trade as a whole then the trade has to be reported. As far as we know most core banking systems reflect two legs.
Banks will have to check with their clients for consensus. We suggest adopting industry best practice.
No, this is not necessary. The SIX Trade Repository system recognises trades that mature naturally. A cancellation would require the trade to be closed on or before the reported maturity date.
Yes, under FMIA there is a possibility to delegate the reporting obligation (as under EMIR). For example, a client in Switzerland can delegate the reporting obligation to a bank in Switzerland.
In general all OTC trades have to be reported to SIX Trade Repository if they are carried out by organizations which are subject to FMIA. If a Swiss bank trades with a foreign bank on a foreign exchange, then the foreign bank has to report to their home repository. If the foreign bank does not report under Swiss law, then the Swiss bank has to report to SIX Trade Repository. It is important that the organizations communicate to each other which side will report.
Only open transactions and positions (if available) where the Pos Quantity ≠0 and the date is in the future, have to be reported on the start date. There is no additional flag of frontloaded transactions however this will be obvious from the execution timestamp when compared to the reporting timestamp.
The field "Unique Transaction Identifier", this means we count per UTI. If the same UTI is used for both a trade and a position, it will be double counted. Check the Price List for further details
Reporting Workflow
- Reporting Firm ID
- Unique Identifier
- Level (this is also used as we allow firms to use the same UTI for both a transaction and the resulting position, this is not recommended).
Action Type "E" can be used. If a client wants to re-book he can use action type "N" and a new UTI.
No, it doesn’t need to match because non-V relevant data is ignored (except of course the fields required to identify the trade).
If you can't find the answers to your question, please don't hesitate to contact one of our experts.
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Trade Repository Client Support
Please contact our Helpdesk for general inquiries about our Trade Repository service. Urgent issues related to the production environment will be prioritized and answered as soon as possible. For issues related to the test environment we will respond to your queries within 24 hours. Support Hours: 09:00 - 17:00 CET on Swiss business days.
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Send Inquiry
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SIX Trade Repository AGPfingstweidstrasse 1108021 ZurichSwitzerland
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