ICE Link Regulatory Reporting

for EMIR
January 2014
EMIR Regulatory Reporting Mandate - Background
Article 9 of the of the European Market Infrastructure Regulation (EMIR) mandates
reporting of all derivative contracts to a Trade Repository (TR) that is monitored and
regulated by the European Securities and Markets Authority (ESMA)
EMIR rules apply to any entity established in the EU that is a legal counterparty to a
derivative contract, even when trading with a non-EU counterparty
All derivative trade details that have concluded, modified, or terminated
1
must be reported
to a TR by all trade counterparties by the end of T+1
Mark-to-market is to be reported daily
2
on all open positions, and if cleared, are the values
provided by the Clearing House
All counterparties must agree to a common Unique Trade Identifier (UTI) when reporting
trade details to a TR, typically the agreed identifier from middleware
3
platforms like ICE Link
ESMA defined reporting standards dictates required reporting details such as: standard
trade economic fields, registered Legal Entity Identifiers (LEI), standard contract product
taxonomies, counterparty types
4
(Financial/Non-financial), hedging, and principal role
Reporting to a TR may be delegated to ICE Link to report on behalf of a trade party for
cleared or non-cleared trades

1. Article 9 of EMIR regulation No. 648/2012 (see paragraph 14), mandated derivative contract types are defined in Article 4 & 9
2. Daily Mark-to-Market and Collateral reporting per paragraph 16, required 6 months post mandate start date, excludes trades that are no longer live
3. See the ISDA Unique Trade Identifier (UTI): Generation, Communication, and Matching practices guide, 4 September 2013
4. See Article 2 (sections 8 & 9), Financial or Qualifying Non-Financial Entity, or Non-Financial Entity
3
EMIR Regulatory Reporting Mandate - Timeline
FEB 12 MAY 12 AUG 12 FEB 12 NOV 7

Trade Reporting
Mandate Effective
1


ESMA Adoption of
Trade Repository
Registration
Backload of Pre-Mandate
Open Positions traded
before 16 AUG 2012
2013 2017
2014
Daily Collateral and
Mark-to-Market
Reporting Mandate


Backload of All
2

Pre-Mandate Positions
traded between 16 AUG
2013 and 12 FEB 2014


Mandate for all EU trade counterparties to report all derivative trades to a
Trade Repository is effective
1
on February 12, 2014
Pre-mandate open trade positions are mandated to be backloaded to a
Trade Repository on May 12, 2014, and all positions 3 years after the initial
reporting mandate
2

Daily reporting of collateral and mark-to-market of open positions is
mandated on August 12, 2014
1. Mandate effective 5 working days + 90 days post TR Registration Adoption
2. Article 3 of Regulation (EU) 148/2013
EMIR Offering
4
5
ICE Link Uniquely Positioned for EMIR Reporting
* Bilateral: Includes both direct and Prime Broker Intermediated trades
** Daily MTM and Collateral reporting start date 6 months post EMIR TR reporting start date

Cleared or
Bilateral*
Reportable Events
Event
Initiator
Event
Available in
ICE Link
Event
Available in
Confirm
System
UTI Generation UTI Communication
ICE Link TR
Submission
Supported TR
NEW TRADE-UNALLOCATED BLOCK Dealer Y N Dealer/ICE Link ICE Link Y DTCC Europe
NEW TRADE-ALLOCATION Client Y Y ICE Link ICE Link Y DTCC Europe
NOVATION Client Y Y ICE Link ICE Link Y DTCC Europe
TERMINATION Client Y Y Dealer/ICE Link ICE Link Y DTCC Europe
SEF SEF Y Y SEF ICE Link Y DTCC Europe
AMENDMENT Dealer Y Y Dealer/ICE Link ICE Link Y DTCC Europe
CREDIT & SUCCESSION EVENT TIW Y Y N/A ICE Link Y DTCC Europe
NEW TRADE-UNALLOCATED BLOCK Dealer Y N Dealer/ICE Link ICE Link Y TV Europe
CLEARED TRADE (BETA/GAMMA) CCP Y N CCP ICE Link Y TV Europe
SEF SEF Y N SEF ICE Link Y TV Europe
DAILY MTM & COLLATERAL VALUATION** CCP Y N CCP ICE Link Y TV Europe
NETTING CCP Y N CCP ICE Link Y TV Europe
TRANSFER CCP Y N CCP ICE Link Y TV Europe
CREDIT & SUCCESSION EVENT CCP Y N CCP ICE Link Y TV Europe
Bilateral
ICE Cleared
6
EMIR Regulatory Reporting Mandate ICE Link Offering
ICE Link offers market participants a regulatory reporting compliance solution
Satisfies ESMA requirements for EMIR Trade Reporting to a Trade Repository
Determines which workflows and events are reportable
Stores all required static data relevant to regulatory reporting
Trade Repository report generated and submitted upon ICE Link affirmation
1

Communicates and generates UTI per ISDA UTI guidelines
2

API and web GUI regulatory reporting functionality
Supported for all CDS products and workflows in ICE Link
Cleared Trades: Self Clearing and Clearing Brokered
Non-Cleared, Bilateral and PB: New Trades, Novations, and Terminations
SEF and Off-facility Trade reporting
Minimal effort to adopt, no change to existing ICE Link workflows

Introduced in ICE Link 5.9
Provide ESMA reporting submission capabilities for the February 12
th
compliance date
Support for dual jurisdiction reporting (e.g. CFTC and ESMA) for trade parties
Incorporate UTI Generating Party logic per ISDA guidelines
Automatic enrichment of ESMA defined required static in reports (i.e. ESMA product
taxonomies, LEI/Namespace, Financial Entity, Clearing Thresholds, etc.)
ICE clearing houses report ESMA jurisdiction cleared trades to ICE Trade Vault Europe
2. See the ISDA Unique Trade Identifier (UTI): Generation, Communication, and Matching practices guide, 15 July 2013
1. ICE Link offers an exception process to allow for a regulatory report submission for pending (i.e. non-affirmed) transactions that have reached the T+1 end of day report deadline
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EMIR Specific Reporting Data, Logic, Static Support
Key Reporting Data Attributes
Trade Economics
Execution/Clearing Date & Time
ESMA Product Taxonomy
Legal Entity Identifier (LEI) Mapping
UTI & Namespace/LEI prefix
Reporting Jurisdiction
Principal/Agent Trading Capacity
Beneficiary
Treasury/Commercial Activity
Collateral / MTM valuation
Collateral Portfolio Code
TR Counterparty Name Disclosure
TR Destination and Submission Time

Key Reporting Logic and Static
All reporting fields can be sourced from
existing workflow, static values and
defaults
UTI generation and communication logic
per ISDA guidelines
Reporting based on jurisdiction of
entities in trade / allocations
Entity Static
Corporate Sector
Financial/Non-Financial
Domicile/Jurisdiction
Clearing Threshold (above/below)
Default Values
Treasury/Commercial Activity
Principal/Agent Trading Capacity
Beneficiary
Collateralization
8
EMIR Regulatory Reporting Mandate ICE Cleared Trade Reporting
ICE Clear Credit and ICE Clear Europe (CCP) report all cleared trades for all trade parties
to an SDR for CFTC jurisdiction entities
ICE Clear Credit and ICE Clear Europe (CCP) will provide a delegated reporting model that
provides reporting submissions on behalf of Clients and Clearing Members (CM) that are
ESMA jurisdiction entities
CH provides USI/UTI for all cleared trades
CCP vs. CM report
CM vs. Client report
Reports are submitted to the Trade Repository upon clearing acceptance
Aside of new cleared trades, the CH reports post clearing events including:
Netting/Compression Events
MTM and Collateral Valuations
Transfers
Succession & Credit Events
9
EMIR Regulatory Reporting Mandate UTI Generating Party
ICE Link in role of middleware always communicates the Unique Trade Identifier (UTI)
for all bilateral and cleared workflows
For Cleared trades, the ICE clearing house is always the UTI Generating Party (GP)
Two UTIs are generated for Client cleared trades: CCP-CM and CM-Client
For Non-Cleared trades, ICE Link calculates which trade counterparty is the UTI GP per
ISDA best practices guidelines
USI as UTI logic for trades that fall under dual jurisdiction (CFTC,ESMA) reporting
If the counterparty is not under CFTC or ESMA jurisdiction, the party under ESMA
jurisdiction is the UTI GP
Protection (Floating Rate) Seller is the UTI GP per tie-breaker logic
ICE Link will be the UTI Generating Party if neither trade party provides a UTI
Is CFTC
Eligible?
# of Trade Parties
providing a value
# of Trade Parties under
ESMA Jurisdiction
UTI
Y 0 Either one or both Validation error, RCP is required to provide
Y Either one or both Either one or both Always the USI of the party that is the RCP
N 0 Either one or both ICE Link-generated value
N 1 Either one or both Value provided by party
N 2 1 Value provided by EMIR party
N 2 2 Value provided by Seller
UTI Generating Party Logic
10
Workflows
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EMIR Regulatory Reporting Mandate Clearing Workflow
1. Swap Dealer alleges trade to Buy-side
client who designates their Clearing Broker
(CB)
2. Buy-side client affirms block details and
provides allocations with a designated
Clearing Broker (CB)
3. Buy-side client allocations routed to CBs
for clearing consent, upon consent to clear
the trade, the trades are submitted to the
Clearing House (CCP)
4. Clearing House (CCP) provides the
cleared and confirmed status to all parties
5. ICE Link reports the bilateral (alpha) trade
between the Dealer and Buy-side to the
TR and the Clearing House (CCP) reports
the below to the ICE TR
CCP vs. Dealer CB
Dealer CB vs. Dealer
CCP vs. Buyside CB
Buyside CB vs. Buyside
6. Post clearing reporting, the Clearing
House reports the daily MTM and collateral
calculations for cleared trades
Post Clearing Note: The clearing house also regulatory reports Netting, Transfer, Succession/Credit Event Updates
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EMIR Regulatory Reporting Mandate Bilateral Workflow
1. Swap Dealer alleges trade to Buy-side
client
2. Buy-side client affirms block details and
provides allocations
3. ICE Link designates the trade as
Affirmed and provides the block and the
allocation UTI/details; ICE Link submits
the block trade and the allocations to
the Trade Repository
13
EMIR Regulatory Reporting Mandate Novation Consent
1. Buy-side client alleges Novation to
Transferee Dealer
2. The Transferee Dealer affirms the
novation trade
3. The Remaining Party Dealer affirms to
consent to the novation trade
4. ICE Link designates the trade as
Affirmed and reports a termination of the
original Buy-side vs. Dealer trade and
reports the new Remaining Party vs.
Transferee Dealer trade to the Trade
Repository
14
EMIR Regulatory Reporting Mandate Advantages of Using ICE Link
Satisfies all reporting requirements using existing workflow event details, static data, and
entity defaults, providing a no-work solution for clients
Eliminates the need to develop complex UTI generating and communication logic per
ISDA guidelines
Provides the connectivity and automatic reporting of trades to Trade Repositories (TR),
reducing the need to build out added complex system integrations
ICE Link already submits for almost all clients to MarkitSERV DSMatch for Confirmation
reporting of bilateral trades
Removes the extremely difficult task of the need to track various data sources and TRs
for each lifecycle workflow
No additional ICE Link fees
Additional Documentation, Client Support, Questions
15
To access additional documents such as the ICE Link EMIR Regulatory
Reporting Concepts document, the ICE Link EMIR Reporting API Guide, or
the ICE Link EMIR Reporting Data Elements, please go to the ICE Link
community page at www.theice.com/community

ICE OTC Sales Contact Details

North America +1 212 323 6020

Europe/Asia/Australia +44(0)20 7429 4500

Email: ICEsales.OTCFinancial@theice.com

API Integrated Users: Integrate Support Portal at www.theice.com/integrate