Report Timings

Matching Reports Across Different Time Zones

Status: Best Practice Finalised, Last Updated: 26/04/2021

Question:
How will counterparts in different time zones reconcile time and date fields within SFTR?

Best Practice:
All date and time fields should be reported in Universal Coordinated Time (UTC).

For Field 2.12 (Execution Timestamp), timestamps are typically logged for each trade as they are booked in the trade capture systems, not necessarily when the trade was agreed with the counterparty. Therefore there may be discrepancies between the two timestamps, which cannot be amended due to the nature of trade capture systems.

In discussing this with the ISLA SFTR Working Group, the group contemplated creating a new field to upload timestamp data in case of breaks with counterparties, as they assume all will be using the same interpretation of the timestamp, i.e. when the trade was booked.

Reporting participants will need to be careful to use UTC to report their timestamps from their systems to avoid breaks where counterparties are in different time zones.

Also, see related best practise SFTR-192 and SFTR-236 . (SFTR-208)

Execution Timestamp for Voice Trades

Status: Best Practice Finalised, Last Updated: 26/04/2021

Question:
Both counterparts to a loan transaction must book the concluded transaction within 1 hour of execution. If one or both sides fail to book the within 1 hour of the other the trade will not match. How do you agree who has the correct timestamp?

Best Practice:
Proving actual transaction conclusion could either be determined by reviewing voice recordings, emails, Bloomberg confirms, etc. This would be impractical other than to resolve conflicts.

It is therefore recommended that all voice-executed SFTs be booked immediately into the relevant system to capture the correct execution time and thereby remain within tolerance.

If a transaction is not booked within an hour of execution then, when it is booked, the booking system should be capable of storing the actual execution time rather than the booking time. (SFTR-192)

Working Days, Public Holidays, and Calendar Best Practice

Status: Best Practice Finalised, Last Updated: 26/04/2021

Question:
What is the best practice for reporting on working days and public holidays?

Best Practice:
ESMA clarified their position on working days and holidays in their Q&A on SFTR Reporting 5th November 2020.

1) Where "T" = "Today" and not "Trade Date", reportable events should be reported no later than close of business local time on T+1 for the entity with the reporting obligation, excluding weekends and public holidays. To determine whether a day is a working day or a holiday, participants should refer to the local calendar of the member state they are operating from.

Therefore, if trading on a Friday and there is a UK public holiday on the Monday, report no later than Tuesday where the participant is UK domiciled. If the other counterparty is not UK domiciled and has no public holiday constraints, they should report no later than Monday.

If an SFT is traded on a public holiday and there is other relevant trade activity then report on a normal T+1 basis, as the TR would expect to report COLU and VALU reports as per standard reporting deadlines whether public holidays or not.

2) If internal systems do not allow reporting to be determined by a holiday calendar, then report on standard weekdays (i.e. report on bank holiday Monday if required).

3) Regarding Middle East and Far East weekend markets; if a trade is concluded on a Friday or Sunday for an eligible client, then report as per the calendar if the EU member state being transacted with (i.e. on the next EU working day). (SFTR-187)