Post on 20-Feb-2021
© DTCC
GTR MAS Reporting Code of Practice REIT Manager/Trustee Setup Model
Last Updated: 30 May 2014
© DTCC
Structure
2
Topic Page
I. Background and Functionality ………………………………………… 3 II. Potential Compliance Timelines ………………………………………. 4 III. Submission Scenarios - Reporting Obligation
on REIT Manager ……..………………………………………………….. 5 IV. Submission Guidelines for REIT Manager ...………………………... 6 V. Submission Scenarios - Reporting Obligation on Trustee ...…….. 10 VI. Submission Guidelines for Trustee ………...………………………... 11 VII. Regulator Outputs ……………………………………………………….. 15
© DTCC
Background and Functionality
3
GTR Functionality
Firms can submit and reconcile their trades directly in DTCC’s trade repository. This would be considered a direct submission by the REIT Manager/Trustee or the REIT/Trust
Firms can also choose to delegate their reporting to their counterparty or a third party, who in turn, will report to DTCC
Regardless of the submission method, the party with the MAS reporting obligation and the party of the reportable trade, would need to be onboarded to DDRS (DTCC Data Repository (Singapore) Pte. Ltd.).
Both REIT Manager/Trustee and the REIT/Trust would need to register for a LEI
Submissions should be made using standard DTCC trade submission templates
This document assumes the MAS reporting obligation falls on the REIT Manager or Trustee
Background
Under MAS regulations all OTC trades must be reported to a trade repository. The reporting obligation for 2014 covers Interest Rate and Credit Derivatives asset classes. DTCC provides a number of simple reporting options for compliance with MAS reporting requirements. DTCC offers a centralized and flexible trade reporting solution for participants looking to meet their reporting obligations under MAS. This document is meant to be a guide for REIT Managers and Trustees, who have the reporting obligation MAS.
© DTCC
Potential Compliance Timelines
4
Firms should consult with their internal legal and compliance team to ascertain their own reporting obligation and compliance date. The table below is simply a guideline.
# Scenario Booked In Singapore? Traded in
Singapore?
Possible “Specified Person” (Reporting
Obligation under MAS)
Legal Entity/Party of the Trade
Investment Manager
Reporting Requirement (according to MAS Rules)
1 Singapore based REIT Manager with a Singapore based Trust/Trustee
Yes Yes REIT Manager / Trustee Trust REIT Manager 1-Jul-14
2 Singapore based REIT Manager with an Offshore Trust
No Yes REIT Manager / Trustee (Offshore) Trust REIT Manager 1-Jul-15
3 Singapore based REIT managed by a Singapore based REIT manager
Yes Yes REIT Manager / Trustee REIT REIT Manager 1-Jul-14
4 Offshore REIT managed by a Singapore based REIT manager
No Yes REIT Manager / Trustee (Offshore) REIT REIT Manager 1-Jul-15
1
2
3
4
* Each scenario has very specific setup and submission requirements
© DTCC
Submission Scenarios – Reporting Obligation on REIT Manager
5
Submission can be done directly to the GTR, or can be delegated. Firms would need to communicate with the appropriate parties if they choose to delegate.
* Each scenario has very specific setup and submission requirements
Who has the reporting
obligation?
Who is the Legal Party of the trade?
Who will submit the trade? Scenario #
REIT Manager Trust / REIT
Trust / REIT R4
Third Party R3
Counterparty R2
REIT Manager R1
© DTCC
Submission Guideline for REIT Obligation - R1
6
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT, if onboarded directly to DDRS
If Trust / REIT is onboarded through the REIT Manager, then REIT Manager
* Either directly or through the REIT Manager (as multi managed)
Data fields of the inbound submission should contain: Data Submitter – LEI of REIT Manager Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of REIT Manager
LEI Required? Onboard to DDRS?
REIT Manager Yes Yes
Trust / REIT Yes Yes*
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
REIT Manager Trust / REIT Trust / REIT Counterparty REIT Manager MAS
© DTCC
Submission Guideline for REIT Obligation - R2
7
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT, if onboarded directly to DDRS
If Trust / REIT is onboarded through the REIT Manager, then REIT Manager
* Either directly or through the REIT Manager (as multi managed)
Data fields of the inbound submission should contain: Data Submitter – LEI of Counterparty Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Counterparty Trade Party 2 – LEI of Trust / REIT Execution Agent Party 1 – LEI of REIT Manager
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Counterparty Trust / REIT Counterparty Trust / REIT REIT Manager MAS
LEI Required? Onboard to DDRS?
REIT Manager Yes Yes
Trust / REIT Yes Yes*
© DTCC
Submission Guideline for REIT Obligation - R3
8
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT, if onboarded directly to DDRS
If Trust / REIT is onboarded through the REIT Manager, then REIT Manager
* Either directly or through the REIT Manager (as multi managed)
Data fields of the inbound submission should contain: Data Submitter – DTCC Account of Third Party Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of REIT Manager
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Third Party Trust / REIT Trust / REIT Counterparty REIT Manager MAS
LEI Required? Onboard to DDRS?
REIT Manager Yes Yes
Trust / REIT Yes Yes*
© DTCC
Submission Guideline for REIT Obligation - R4
9
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT
Data fields of the inbound submission should contain: Data Submitter – LEI of Trust / REIT Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of REIT Manager
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Trust / REIT Trust / REIT Trust / REIT Counterparty REIT Manager MAS
LEI Required? Onboard to DDRS?
REIT Manager Yes Yes
Trust / REIT Yes Yes
© DTCC
Submission Scenarios – Reporting Obligation on REIT Manager
10
Submission can be done directly to the GTR, or can be delegated. Firms would need to communicate with the appropriate parties if they choose to delegate.
* Each scenario has very specific setup and submission requirements
Who has the reporting
obligation?
Who is the Legal Party of the trade?
Who will submit the trade? Scenario #
Trustee Trust / REIT
Third Party T4
Counterparty T3
Trust / REIT T2
Trustee T1
© DTCC
Submission Guideline for Trustee Obligation – T1
11
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT, if onboarded directly to DDRS
If Trust / REIT is onboarded through the Trustee, then Trustee
* Either directly or through the REIT Manager (as multi managed)
Data fields of the inbound submission should contain: Data Submitter – LEI of Trustee Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of Trustee
LEI Required? Onboard to DDRS?
Trustee Yes Yes
Trust / REIT Yes Yes*
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Trustee Trust / REIT Trust / REIT Counterparty Trustee MAS
© DTCC
Submission Guideline for Trustee Obligation – T2
12
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT
Data fields of the inbound submission should contain: Data Submitter – LEI of Trust / LEI Submitted For – LEI of Trust / LEI Trade Party 1 – LEI of Trust / LEI Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of Trustee
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Trust / REIT Trust / REIT Trust / REIT Counterparty Trustee MAS
LEI Required? Onboard to DDRS?
Trustee Yes Yes
Trust / REIT Yes Yes
© DTCC
Submission Guideline for Trustee Obligation – T3
13
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT, if onboarded directly to DDRS
If Trust / REIT is onboarded through the Trustee, then Trustee
* Either directly or through the REIT Manager (as multi managed)
Data fields of the inbound submission should contain: Data Submitter – LEI of Counterparty Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Counterparty Trade Party 2 – LEI of Trust / REIT Execution Agent Party 1 – LEI of Trustee
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Counterparty Trust / REIT Counterparty Trust / REIT Trustee MAS
LEI Required? Onboard to DDRS?
Trustee Yes Yes
Trust / REIT Yes Yes*
© DTCC
Submission Guideline for Trustee Obligation – T4
14
Inbound Submission
Setup and Onboarding Requirements DDRS Invoice
EOM DDRS Invoice would be sent to:
Trust / REIT, if onboarded directly to DDRS
If Trust / REIT is onboarded through the Trustee, then Trustee
Data fields of the inbound submission should contain: Data Submitter – DTCC Account (or LEI) of Third Party Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of Trustee
Data Submitter
Submitted For
Trade Party 1
Trade Party 2
Execution Agent Party 1
Execution Agent Party 2
Trade Party 1 Reporting Obligation
Trade Party 2 Reporting Obligation
Third Party Trust / REIT Trust / REIT Counterparty Trustee MAS
* Either directly or through the REIT Manager (as multi managed)
LEI Required? Onboard to DDRS?
Trustee Yes Yes
Trust / REIT Yes Yes*
© DTCC
Regulator Outputs
15
A LEI should be used to identify the REIT Manager/Trustee in all the above scenarios
If either “Execution Agent Party 1” or “Execution Agent Party 2” are populated, the populated values will be reflected on the Regulator Reports.
– Specifically the following fields must be reported: – Execution Agent Party 1 Prefix, and; – Execution Agent Party 1 Value
or; – Execution Agent Party 2 Prefix, and; – Execution Agent Party 2 Value
The ‘Reporting Obligation’ in the regular report would refer to the reporting obligation of the position, not the party
– Eg: If the Trade Party 1 Reporting Obligation is indicated as ‘MAS’ and the Trade Party 1 is not a MAS reportable entity, then the reporting obligation would be the Execution Agent Party 1
1
2
3
Slide Number 1StructureBackground and FunctionalityPotential Compliance TimelinesSubmission Scenarios – Reporting Obligation on �REIT ManagerSubmission Guideline for REIT Obligation - R1Submission Guideline for REIT Obligation - R2Submission Guideline for REIT Obligation - R3Submission Guideline for REIT Obligation - R4Submission Scenarios – Reporting Obligation on �REIT ManagerSubmission Guideline for Trustee Obligation – T1Submission Guideline for Trustee Obligation – T2Submission Guideline for Trustee Obligation – T3Submission Guideline for Trustee Obligation – T4Regulator Outputs