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What is Brexit?

The UK voted to leave the European Union (EU) in a referendum on 23 June 2016. The UK is scheduled to depart on 29 March 2019 with negotiations about future relations between the UK and the EU currently taking place. 

How is DTCC responding?

Prior to Brexit, DTCC’s Global Trade Repository (GTR) service for the European Union will remain via DTCC Derivatives Repository Plc (DDRL), its London based entity. On Brexit date, GTR will offer EU/European Market Infrastructure Regulation (EMIR) compliant reporting via its European Securities Markets Authority (ESMA) authorised Dublin based entity, DTCC Data Repository (Ireland) Plc (DDRIE). DDRL will then, subject to authorization by the UK Financial Conduct Authority (FCA), become an FCA authorised Trade Repository offering FCA/EMIR compliant reporting for the UK.

Read the press release.

Committed to supporting our clients

We want to assure our clients that post-Brexit, DTCC will offer fully-compliant reporting solutions in both the UK and the EU. As the regulations evolve, DTCC will work closely with clients and regulators to ensure ongoing compliance in each jurisdiction, but on day one (the first day of reporting post-Brexit is currently scheduled to be 1st April 2019), the reporting solutions for ESMA and the FCA will be identical. Depending on a client’s post-Brexit business plan, clients may need legal entity identifiers (LEIs) in either or both of the two jurisdictions to support their planned activity and they will need onboarded accounts (existing or new) in each of the locations from which they intend to discharge their reporting obligation(s).

Both ESMA and the FCA have advised trade repositories to assume there will be a hard Brexit (i.e., no transition period) and to plan accordingly. As a result, we anticipate the first day of post-Brexit reporting in both EU and the UK to be 1st April 2019 and are working toward this deadline for service availability in both jurisdictions.

Current & Future State Legal Structure

What do GTR clients need to do?

We are here to support clients every step of the way as Brexit implementation approaches. Here is an overview of the steps that will need to be taken:

  • Onboard reporting legal entities to the correct trade repository to enable all relevant post-Brexit reporting. Clients will need to be onboarded to DDRL (UK trade repository) for FCA reporting and to DDRIE (EU27 trade repository) for ESMA reporting.
  • Ensure all open positions are held in the relevant trade repository from 1st April 2019.
  • Ensure all closed positions are held in the relevant trade repository from 1st April 2019.

We are working with the regulators in both jurisdictions to fully understand how these steps can be undertaken with least risk to the quality of the underlying data.

Timeline of Actions Clients Need to Take