Slide 1: CME European Trade Repository: Alternative Investment Fund Managers Directive (AIFMD)
CME European Trade Repository Alternative Investment Fund Managers Directive (AIFMD)" CME Global Repository Services! May 2014! !
Slide 2: Why is EMIR relevant for funds and fund managers?
Why is EMIR relevant for funds and fund managers?" Overview" The reporting • The European Market Infrastructure Regulation 648/2012 (EMIR) introduced a requirement for counterparties and central counterparties to derivative transactions obligation under EMIR:! (including the conclusion, modification
Slide 3: Is my non-EU fund in scope for the EMIR reporting obligation?
Is my non-EU fund in scope for the EMIR reporting obligation?" "Is the fund an AIF? " In order for the reporting obligation to apply, the fund must be an AIF. ! An AIF is defined as a collective investment undertaking that raises capital from a number of investors; invests that capital for the benef
Slide 4: Is my non-EU fund in scope for the EMIR reporting obligations?
Is my non-EU fund in scope for the EMIR reporting obligations?" "Is the manager of the AIF an AIFM authorised or registered under AIFMD?" A non-EU fund will only be subject to the reporting requirements where it is an AIF and its manager becomes authorised or registered as an AIFM under AIFMD, in wh
Slide 5: Summary of key points
Is my non-EU fund in scope for the EMIR reporting obligations?" "Summary of key points" Whilst funds which are based outside of the EU are generally classified as third country entities and exempted from EMIR requirements, they will become subject to the reporting requirement where they are classifi
Slide 6: What is the EMIR reporting obligation?
What is the EMIR reporting obligation?" Overview " What must be reported?" • All derivatives executed and any modification or termination; eventually collateral! • Includes Exchange Traded Derivatives (ETD) and Over-The- Counter (OTC)! • Asset Classes: Rates, Credit, FX, Commodities, and Equities! B
Slide 7: When will the reporting obligation kick in? Key dates
When will the reporting obligation kick in?" "Key dates" "Whilst the reporting obligations went live on 12 February 2014, they will only apply to a non- EU fund (provided it falls within the definition of an AIF) once its manager has been authorised or registered under AIFMD. ! Non-EU AIFs with an E
Slide 8: Timeline of key dates
When will the reporting obligation kick in?" "Timeline of key dates" ! 12 February 2014" 22 July 2013" Obligation for relevant managers to EMIR reporting 21 July 2014" obligation begins! Deadline for relevant EU become authorised or registered as AIFMs kicks in – EU managers can managers to apply fo
Slide 9: Will the EMIR reporting constitute a breach of any confidentiality obligations?
Will the EMIR reporting constitute a breach of any confidentiality obligations?" Disclosure waivers" Although EMIR seeks to address disclosure issues, entities subject to the reporting obligation may wish to look to obtain a disclosure waiver from their derivative counterparties before proceeding to
Slide 10: Further considerations for funds managed by an AIFM
Further considerations for funds managed by an AIFM" Reclassification" Where a manager becomes authorised or registered under AIFMD, all of the AIFs that are managed or marketed by that manager will be reclassified from third country entities or NFCs to FCs for the purposes of EMIR. ! Exposure to wi
Slide 11: How can I fulfil my reporting obligation?
How can I fulfil my reporting obligation?" Self-reporting" Delegated reporting" ! ! Report directly to the CME European CME Clearing and CME Clearing Trade Repository (CME ETR) or Europe offer a delegated service for another TR registered with ESMA.! EMIR trade reporting to CME ETR. ! More informati
Slide 12: CME ETR service
CME ETR service" " Multi-asset class offering" An ESMA approved TR covering all bilateral exchange traded and OTC products across all asset classes: interest rate, FX, credit, equities and commodities! European based solution" London based legal entity with local business and support staff! Cost eff
Slide 13: User onboarding steps and next steps
User onboarding steps and next steps" " " Register with an Complete User LOU for an LEI" Report using CME Agreement " ETR systems " www.leiroc.org/publications/ Applications to be sent to: gls/lou_20131003_2.pdf! ETRRegistration@cmegrou " ! p.com! ! © 2013 CME Group. All rights reserved. ! 13!
Slide 14: CME ETR user interface
CME ETR user interface" Facilitates upload of CSV files to CME ETR to comply with all reporting obligations! Ad hoc flexible reporting downloading capabilities – reconciliation reports customisable by any field! Supports cleared and bilateral transactions! Customise and save queries for streamlined
Slide 15: European Trade Repository Fee Schedule
European Trade Repository Fee Schedule*" Visit cmegroup.com/ETRFees for complete schedule CME" Approach Fees charged on a one-‐0me basis to each side of transac0on with a new UTI Asset Classes Serviced Rates | Credit | FX | Commodi0es | Equi0es Charge Per side of transac0on Who to Charge Charge to
Slide 16: Connectivity
Connectivity" Approach" • Real-time systems ! • Leverage ClearPort gateway & workflows! • Universal front end experience (API and CSV)! • Back end support of multi-jurisdictional reporting complexities! API Submission" • ClearPort API (FIXML) over MQ or HTTPS web services! • Leveraging ClearPort API
Slide 17: ESMA identifiers
ESMA identifiers" Entity codes – LEI" • Interim ID – any interim solution that is adopted for European entities subject to the reporting obligation needs to be in line with the technical specifications agreed by the Financial Stability Board ! • Once endorsed, LEIs will ID all financials, NFC, broke
Slide 18: Disclaimer
Disclaimer" CME Group”, “CME Europe”, “CME Global Repository Services”, “CME European Trade Repository” and “CME Clearing Europe” are brands of CME Group Inc. and its subsidiaries, members of which include Chicago Mercantile Exchange Inc., CME Europe Limited, CME Clearing Europe Limited, CME Trade R