Agency Lending Example:

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Status: Best Practice Finalised, Last Updated: 15/02/2024

Question:
Agency Lending Example:

This is an example where back reporting is lost in translation:

1. 1. AL sends borrower allocation A for a new trade on the last day pre-outage (Day 1).

   • Trade remains open through outage and borrowers sends daily VALU, COLU or MODI reports to that trade using allocation A’s LEI and UTI throughout the outage (let's say that’s Day 2 through Day 20).
   • On resumption of service it turns out Allocation A was reallocated out of the trade early in the outage and replaced with Allocation B with a new UTI And LEI (Day 3 let's say).
   • Even if back reporting is correctly done it means the borrower will be sending a ETRM for Allocation A back dated to Day 3 but they will already have sent/reported previously VALU, COLU and MODI messages on the trade for days 4, 5,6 etc. all the way through, to Day 20.

     • There does not seem any obvious validation rules that would stop the ETRM for allocation A being submitted with event date of Day 3.
     • Its not obvious to suggest the previous data will be automatically cleared up so effectively would have a trade in the TR with a ETRM of Day 3 but lifecycle events all the way through to Day 20.
     • From a regulators perspective if they were to go back through the data using this example, they would see a trade opened, a few lifecycle events, a termination then many more days of lifecycle events dated after the trade closed. It could be asked what value this is.

   • 2. In this example its is suggested that it should be a case of the member highlighting how their reporting model worked during the outage. Even if the trade is not terminated regulators may highlight how MODI/VALU/COLU values were reported without the infrastructure in place for data transfer.

Best Practice:
(SFTR-837)