MAS REWRITE

On 21st October 2024, the Monetary Authority of Singapore (MAS) Securities and Futures (Reporting of Derivatives Contracts) Regulations 2024 goes live on the same day as ASIC REWRITE and shortly after the UK rollout of EMIR REFIT.  

MAS’s current Securities and Futures Regime was introduced in 2013 as a way of Singapore responding to the G20 agreement, where there was a mandate of reporting all OTC derivatives. MAS has consistently updated its regime in stages based on the asset class involved and the size/type of firm involved. 

These new rules, known as MAS REWRITE, is a comprehensive revision to its existing regime with the aim of aligning with global standards, increasing transparency and incorporating feedback from reporting entities. The process of MAS REWRITE began in July 2021 with their Consultation Paper on Proposed Amendments to their regime and will be finalized when it goes live in October. 

What changes does MAS REWRITE? The revision mandates several critical adjustments that organisations must adhere to or face severe penalties and damage to their reputation.

These changes include: 

• ISO 20022 XML Data Format: The MAS Rewrite mandates the adoption of a new reporting format, leveraging the ISO 20022 messaging standard. This standardized format streamlines data exchange and improves interoperability between market participants and regulatory authorities.

• Unique Trade Identifier (UTI) and Unique Product Identifier (UPI): Introduction of more detailed transaction and instrument information to improve traceability and risk assessment. These will have identical modalities as those introduced in other jurisdictions such as the EU, the UK, the ASIC and the USA.

• Event Type and Action Type: The combination of these two fields results in dozens of distinct and permissible combinations of values. This significantly alters lifecycle event management, necessitating specific actions within the entity’s reporting system.

• Collateral and Valuation reporting: Introduction of mandatory reporting on the valuation of derivatives and associated collateral, aimed at providing a clearer view of exposure and credit risk.

• New and expanded Reporting Details: In general, market participants are obligated to include additional or expanded details and values in their reports, like the Notional Schedule fields, Spreads and Options related information, information related to Other Payment Types, Package fields, Action Type Revive, Event Types, and more. These enhancements aim to provide regulators with deeper insights into market activities.

• Re-reporting: Re-reporting must take place within six months of go-live. There is an exemption for re-reporting of information that previously was not captured at the point when the contract was executed. No re-reporting is required for contracts with a maturity of less than six months from the go-live date.

• New EoD and Intraday Reports: Counterparties will be receiving streamlined Trade and Margin related intraday and end of day reports, which will empower them by providing enhanced transparency and clarity into their reporting, facilitating their risk management, compliance oversight and informed decision-making.

• T+2 Reporting Deadline: The MAS Rewrite stipulates a T+2 reporting timeline, requiring market participants to submit derivative transaction reports within two business days following the transaction execution date.

• Reporting Significant Issues to Regulatory Authorities: This new requirement mandates the disclosure by the reporting party of any significant issues (defined as reporting obstacles that prevent reporting, misreporting by a reporting system flaw or an issue that causes a large number of rejected reports) encountered during the reporting process. The objective is to enhance regulatory oversight and ensure timely intervention to mitigate potential risks, thereby maintaining the integrity and stability of the financial market.

Frequently Asked Questions on the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 - https://www.mas.gov.sg/-/media/mas/regulations-and-financial-stability/regulations-guidance-and-licensing/securities-futures-and-fund-management/regulations-guidance-and-licensing/faqs/faqs-on-the-securities-and-futures-reporting-of-derivatives-contracts-regulations-2013-4-sep-2024.pdf

Securities and Futures (Reporting of Derivatives Contracts) (Amendment) Regulations 2024 - https://sso.agc.gov.sg/SL-Supp/S410-2024/Published/20240510?DocDate=20240510 

Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 - https://sso.agc.gov.sg/SL/SFA2001-S668-2013 

Guidelines to the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 [SFA 06A-G01] - https://www.mas.gov.sg/-/media/mas/regulations-and-financial-stability/regulations-guidance-and-licensing/securities-futures-and-fund-management/regulations-guidance-and-licensing/guidelines/guidelines-to-the-securities-and-futures-reporting-of-derivatives-contracts-regulations_31-may-24_3.pdf 

Trading Venues for Derivatives Contracts in the United States of America - https://sso.agc.gov.sg/SL/SFA2001-S133-2019?DocDate=20190313 

Securities and Futures (Clearing of Derivatives Contracts) Regulations 2018 - https://sso.agc.gov.sg/SL-Supp/S680-2019/Published/20191010?DocDate=20191010 

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