EMIR Client Delegated Reporting Support Model

Project Brief

An assignment at very short notice with a top-tier global investment bank to engineer and implement an Operations Support Model for EMIR Client Delegated Reporting (CDR) for all in-scope asset classes ahead of the industry-wide go-live date.
The aim was to deliver the Support Model covering:

• Reporting of trades to the Trade Repository
• Management of lifecycle events
• The implementation of a client communications model in the event of service limitations and transaction reporting failures
• The implementation of an internal business escalation contact matrix in the event of a failure to execute transaction reporting
• The implementation of a Specific Point of Contact (SPOC) model to facilitate incoming client queries
• The validation of existing process controls and the identification of potential control weaknesses

Approach

Team Formation

Formation of a project team comprising senior specialists covering the disciplines of project management, Operations risk and control, regulatory reporting coupled with OTC and Listed Derivatives product knowledge.

Orientation & Familiarisation
The project team were ‘parachuted’ in from another assignment at the client at very short notice, just 1 month before the industry-wide EMIR go-live date. Within one week we verified the project scope, identified and engaged key stakeholders, confirmed Front Office and support systems and produced cross-functional process flows.

Planning

• Defined the methodology and approach for conducting the business analysis required for all in-scope clients and products
• Organised analysis workshops with key stakeholders and subject matter experts
• Defined and delivered a project governance model, communication plans and a Risk, Assumptions, Issues, Dependencies (RAID) Log for tracking and resolution
• Agreed the approach with our sponsor, completing an initial project plan for their approval

Delivery

• Documented and implemented a Day 1 Support Operating Model
• Produced cross-functional flow charts detailing:
  • Client delegated reporting process for all asset classes including management of the DTCC Match Status Report and Acknowledged (ACKs), Non-Acknowledged (NACKs), and Acknowledged with a warning (WACKs) messages including hand-offs between functions
  • Transaction reporting failure – escalation and client communication process including action timelines
  • Service limitation communication flows
  • NACK IT process flows
• Implemented a communication model to notify clients in the event of transaction reporting failures and service limitations
  • Produced wording (verified by Legal Dept.) for notification to clients of service limitations and reporting failures
  • Designed and implemented a secure, web-based application to publish the service limitations and reporting failures for individual client access and usage
• Produced a client query Specific Point of Contact (SPOC) matrix for delegated reporting by functional responsibility e.g. Eligibility, UTI sharing, Match Status Report, Unmatched/Unmatched 1/Unmatched 2 etc.
• Implemented an internal business escalation contact matrix to be used in the event of a failure to execute transaction reporting on behalf of a client(s)
• Produced a control inventory for all applicable systems and information flows, detailing the flow, identifying owners for accountability and responsibility and assigning each control a Red, Amber, Green, (RAG) status
• Upgraded the criticality rating of a key router system to ensure highest priority IT support and response in the instance of a system failure
• Oversaw the IT governance model and process for the remediation of IT NACK messages