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What is Brexit?

The UK voted to leave the European Union (EU) in a referendum on 23 June 2016. The European Parliament has now ratified the Withdrawal Agreement, meaning that all of the legal and technical processes necessary for the UK to leave the EU are now finalized. Therefore, the Withdrawal Agreement will enter into force on February 1, 2020 and a Transition Period will immediately come into effect at that point. The Transition Period is scheduled to last until December 31, 2020.

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 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.

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.
  • Ensure all closed positions are held in the relevant trade repository.

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.