The Monetary Authority of Singapore (MAS) has published its response to feedback received form its consultation on reporting of derivative contracts.  The final requirements now appear in the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013. 

MAS provided comments on the feedback received and has confirmed that:

• there will be a grace period for compliance with the commencement of each reporting phase - the regime will commence on 31 October 2013 for interest rate and credit derivatives.  However, given the grace period,
  the final reporting commencement dates for banks, other financial entities and significant derivatives holders are 1 April, 1 July and 1 October 2014
  respectively.  The grace period is intended to allow entities with sufficient time to resolve technical issues or reporting errors. Reporting of other asset classes of derivative contracts will commence in Phase II after October 2014;
• the definition of "traded in Singapore" - includes trades which are executed by a trading desk that is physically located in Singapore.  MAS will provide further guidance on this and the requisite nexus required;
• the scope of data fields would be narrowed at the commencement stage - MAS will take into consideration industry readiness and international developments before implementing the data fields relating to confirmation, mark-to-market value and collateral in the later part of 2014;
• the reporting timeframe - will be extended to T+2 (Singapore time);
• only trades that are booked in Singapore are to be back loaded – with over reporting permitted;
• it recognises the potential conflicts between its requirements and foreign laws on privacy and confidentiality - MAS will provide temporary exemptions to allow counterparty information to be masked where the requirements of recognised jurisdictions require this. This exemption will expire on 31 October 2014 and unmasking will be required within two months thereafter.  This does not apply to transactions which have expired or are terminated before the expiry date; and
• when calculating the reporting threshold for a significant derivatives holder(SDH) -  a person will qualify as an SDH when either their
  aggregate gross notional amount of specified derivatives contracts booked in
  Singapore exceeds S$8 billion, or when their aggregate gross notional amount of specified derivatives contracts traded in Singapore is greater than that
  sum.  The on-going reporting requirements for SDHs proposed have been
  removed, as MAS is of the view that SDHs should not be subject to stricter
  requirements than other specified persons.  The notification period for
  SDHs has been extended to two months.

 Related Links:

Final requirements

http://www.mas.gov.sg/~/media/MAS/Regulations%20and%20Financial%20Stability/Regulations%20Guidance%20and%20Licensing/Securities%20Futures%20and%20Fund%20Management/Regulations%20Guidance%20and%20Licensing/Regulations/Reporting%20Regs.pdf

Comments

http://www.mas.gov.sg/~/media/MAS/News%20and%20Publications/Consultation%20Papers/Reporting%20consult%20response.pdf