Since the 2008 financial crisis the industry has confronted numerous waves of new and revised regulations and the compliance challenges that go along with them. 和 there’s more to come: headliners for the next two years include the push toward harmonizing derivatives trade reporting standards across jurisdictions, the final phase-in of uncleared margin rules (UMR) and the start of CSDR’s 结算 Discipline Regime (SDR).
Combined with the thicket of rules already on the books – from Dodd-Frank to SFTR – the array of changing and emerging mandates are straining firms’ operations to a heightened degree. 和 when this infrastructure and related control framework is already a patchwork of functionalities from a decade of adapting to regulatory change, 公司正面临着重要的问题:
- When is the right time to upgrade my infrastructure and 控制 to manage compliance with all these regulations?
- 超出时间, how do I tackle this burden in a way that’s manageable and cost efficient for my organization?
- 和, how do I ensure these upgrades will set my firm up more efficiently for future regulatory change and more-rigorous enforcement?
It’s like the situation confronting a homeowner 20 years after she moved in: the kitchen layout and appliances are out of date, 水龙头在漏水, and the family long ago outgrew the breakfast nook tucked into the corner. 增量式或DIY式维修似乎既简单又便宜, but they may fail to pass inspection and only delay the inevitable full-blown renovation that’s required.
当涉及到公司的报告基础设施, 控制和过程, firms should address the needed overhauls in a way that delivers the greatest value and readies them for the regulatory changes taking effect in 2021 and beyond.
长长的待办事项清单
Mapping out the current and forthcoming regulations around transaction reporting, UMR and settlement discipline across multiple jurisdictions can make you dizzy. 监管措施, like the CFTC and SEC’s planned expansion and potential reengineering of the trade reporting construct laid out in 2013, along with more rigorous requirements around liquidity management and settlement for UMR and CSDR, 分别, promise to impose continuing changes to firms’ compliance strategies and responsibilities.
This regulatory landscape will be increasingly difficult to navigate using the processes, 控制, governance and systems that have been built and repeatedly rejiggered over the last 10 years. 为了跟上这种变化，公司必须简化他们的数据集, become more sophisticated in sourcing key data elements related to collateral and unique identifiers, and either create new or upgrade existing measures to mitigate settlement fails.
就像漏水的水龙头, 过时的电器和功能失调的厨房布局, firms will need to deal with their cobbled-together infrastructure; there’s no way around it. 但是知道该做什么并不能解决如何去做.
我的观点
It might be tempting to get by a while longer with incremental fixes and updates that address the demands of individual mandates. This kind of siloed perspective and staggered implementation would be a mistake, for several reasons.
First is the sheer volume of work on the plates of regulatory reporting teams in 2021 and 2022 and the need to stay ahead of compliance deadlines. Second is the likelihood of reporting and compliance overlap as jurisdictions move toward greater harmonization across regulations, 如果零碎地处理升级，可能会导致浪费精力. Third are today’s tighter regulatory standards and more-mature supervision, which make DIY and incremental refits the riskiest and least cost-efficient approach over the long term.
The work ahead seems herculean but here’s another piece of advice: don’t undertake the entire effort on your own. 通过我们新的咨询服务, 存提供深度, cross-functional experience and expertise to guide you in making informed decisions and executing effective plans to enhance performance and reduce risks in your compliance operations.
存咨询服务提供端到端诊断服务, 设计, implementation and project management to establish the best compliance program construct for your firm. 衍生品交易报告, 程序需要考虑新的数据字段, 新vnsr威尼斯城官网登入, 新的流程和控制, 新的利益相关者. UMR requires heightened monitoring and control of liquidity and SDR more-efficient settlement processes. 存 咨询服务 will help you make the complex architectural decisions necessary to operate your program and ensure its future scalability.
而不是被它的巨大压垮, I urge you to frame the task ahead as an opportunity to transform your legacy systems and processes for trade reporting, liquidity management and settlement --simplifying and rationalizing them to suit the increased standardization and harmonization of global regulations. You’ll end up with a scalable, efficient infrastructure that lowers your operating costs and risks.