Join Conran Pearce, Software Engineer at Novatus Global, as he introduces the MAS reporting capabilities of the Novatus En:ACT platform. Designed for Singapore’s MAS compliance, it automates tasks like risk management, AML compliance, and liquidity reporting. By integrating real-time updates, En:ACT simplifies regulatory adherence, helping firms avoid fines, reputational damage, and operational risks.
MAS Reporting with
Novatus Global
Understanding MAS Reporting: Ensuring compliance with Singapore’s derivatives reporting obligations to enhance market transparency and regulatory oversight since 2013.
What is MAS Reporting?
On 31st October 2013, the Monetary Authority of Singapore (MAS) established the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013. This was to align with the G20’s agreement to harmonise OTC derivatives reporting. MAS reporting requires key trade details to be submitted to a licensed Trade Repository (TR) for all OTC derivatives including interest rate, credit, FX, equity and commodity contracts.
Mandating the reporting of derivatives transactions to a licensed trade repository assists in improving market transparency while assisting the MAS with its role in market regulation.
Reporting requirements for these entities are detailed in section 124 of the Act and Section 6 of the Regulations.
MAS reporting regulation mandates the reporting of over-the-counter derivatives, whereas exchange-traded derivatives (ETDs) are exempt. Within MAS reporting regulation, if an entity qualifies as an SDH it has to report. Non-SDH entities are subject to MAS reporting based on their licensing, not AUM.
There are reporting exemptions for Contract for Difference (CFD) brokers who trade with retail counterparties, limiting the number of trades they need to report.
Reporting Deadlines and Requirements:
When booked or traded in Singapore, the following derivative contracts must be reported to a licensed TR within a T+2 reporting deadline:
Interest rates
Credit
Foreign Exchange
Commodities
Equities
As already mentioned, ETDs are exempt from MAS reporting regulations.
The T+2 reporting deadline helps to improve market transparency and allows market regulators to identify emerging risks while maintaining market stability.
Cross-Border Reporting Obligations:
If a derivatives contract is reportable under MAS reporting regulations, it must be reported to a MAS-licensed trade repository, even if already reported in another jurisdiction.
If a reporting entity is unable to file a report in time due to foreign laws restricting the sharing of customer or counterparty information, then reporting can often be deferred. The reporting entity will need to prove it made a reasonable effort to gain the consent required within the allotted time and if so, then reporting can be deferred until consent is received or no longer required, whichever comes first.
If a reporting firm cannot report on a transaction due to cross-border consent issues, it must continue to attempt to gain consent until the report can be filed or consent is no longer needed. Additionally, if a counterparty located outside of Singapore files a report to a TR that is licensed by the MAS, the reporting entity must inform the TR that the contract is also being reported on under Singaporean reporting obligations.
Reporting Deadlines and Requirements:
The MAS Rewrite came into force on the 21st of October 2024. This rewrite brings significant changes to MAS reporting obligations such as:
Identifiers
Introducing Unique Product Identifier (UPI) and Unique Transaction Identifier (UTI) codes will assist with identifying and aggregating transactions reported to TRs.
Standardisation
Adoption of the ISO 20022 XML messaging format to align with global reporting practices.
Simplification
A reduction of reportable fields from 162 fields to 136 fields.
Given the significance of these changes, many firms will likely face issues in adapting to the new reporting obligations.
With this in mind, the MAS has provided guidance for what should be done if firms are struggling to report accurately in a timely manner. For example, if a firm is unable to obtain the final-UTI to meet reporting deadlines, it can create an interim-UTI that is identifiable by the reporting entity. Once the reporting firm has obtained the final-UTI, it should file a new report for the transaction, providing the final-UTI and using the action type “NEWT” and the event type “TRAD”. The report with the interim-UTI should then be marked as “EROR”.
Reporting firms will not be required to submit a final-UTI if the contract has expired or is terminated, but MAS only expects this to happen in exceptional circumstances, and firms need to ensure measures are in place to report all fields in a timely manner.
Firms should prepare by researching the problems caused by the introduction of similar regulatory changes in other jurisdictions and assessing their technical readiness for the upcoming MAS Rewrite regulatory changes.
Consequences of Non-Compliance with MAS Reporting
The MAS has been known to pursue entities that do not comply with reporting standards and other regulatory requirements.
In 2024 so far, the MAS has published the details of action taken against twenty-two individuals or firms, including criminal prosecution, prohibition order and reprimand cases. While these cases aren’t all related to failures in MAS reporting, they show that the MAS invest heavily in monitoring for regulatory compliance issues and taking action against firms or individuals who fall short of regulations.
To ensure compliance and avoid penalties, the MAS encourages firms to conduct regular internal audits and compliance reviews.
Join the many organisations we’ve helped to transform their transaction reporting.
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