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Singapore OTC Derivatives Transaction Reporting Rules (MAS OTCD Reporting)

MAS Refers to the Monetary Authority of Singapore. Like other transaction reporting regimes, Singapore has introduced the OTC Derivatives Transaction Reporting Rules in 2019. These rules apply only to OTC derivatives and cover the following asset classes.

1. Interest Rates
2. Credit
3. Foreign Exchange
4. Commodity; and
5. Equity

The following paragraphs highlight these rules.

Effective Date

The rules became effective for Interest rates and Credit OTC on 1st Oct 2019. For other asset classes, they were supposed to be effective from 1st October 2020 but due to Covid-19, they were postponed to 1st October 2021. Thus, in short.

From 1st October 2019

• Interest Rate OTC Derivatives
• Credit OTC Derivatives

From 1st October 2021

• Foreign Exchange
• Commodity; and
• Equity

Which trades need to be reported?

Only OTC derivatives trades traded or booked in Singapore need to be reported. Exchange derivatives are exempted from this reporting. Not all OTC derivative trades need to be reported. OTC FX Forwards involving physical settlement are exempted from reporting requirements.

Who should report the transactions (covered parties)?

Only "significant derivatives holders" have to report their derivative trades. The "Singapore Securities and Futures Act" is the underlying regulation for these rules. The Act has not defined the term "significant derivatives holder" but has used the words "specified persons" to list out the applicable or covered parties. As per the act, the following are the specified persons.

1. any bank that is licensed under the Banking Act of Singapore
2. any subsidiary of a bank incorporated in Singapore
3. any merchant bank approved as a financial institution under the Monetary Authority of Singapore Act
4. any finance company licensed under the Finance Company Act
5. any insurer licensed under the Insurance Act
6. any holder of capital market services license; and
7. any other persons who can be included by the MAS Authorities

In short, retail participants are excluded from this regulation. Only institutions are covered in this. However, not all institutions are covered either; currently, only those institutions whose aggregate gross notional amount of OTC derivatives exceed SGD 8 billion are covered.

Exemptions from Transaction Reporting Obligations

The following entities are exempted from these regulations.

• an approved trustee
• a licensed trust company
• a subsidary of a bank incorporated in Singapore which has carried on its business or operations for less than 4 consecutive quarters.
  • which has carried on its business or operations for less than 4 consecutive quarters; or
  • if a threshold of SGD 5 billion for the aggregate gross notional amount is met
• an insurance company
  • which has carried on its business or operations for less than 4 consecutive quarters
  • if the threshold of SGD 5 billion for the aggregate gross notional amount is met
• a CMSL:
  • which has carried on its business or operations for less than 4 consecutive quarters
  • if the threshold of SGD 5 billion for the aggregated gross notional amount is met; or
  • if the counterparty to the relevant SDC is not an accredited investor or an institutional investor (i.e. retail investors)
  • persons specified in the regulations, including the Singapore government, central banks, multilateral development agencies and international organisations.

SGD 5 billion threshold
This threshold is only applicable if the counterparty to the relevant SDCs is an accredited investor or institutional investor (i.e. not a retail investor). The CMSL holder's aggregate gross notional amount of the SDCs to which it is a party or which it executes or causes to be executed as an agent of a party to the contract for the year ending on the last day of a quarter, does not exceed SGD 5 billion for:

• the most recent completed quarter; and
• each of the 3 consecutive quarters immediately preceeding that quarter

What information need to be reported?

The following information needs to be reported.

1. Contract information such as Unique Transaction Identifier (UTI)
2. Counterparty information such as Legal Entity Identifier (LEI)
3. Clearing information
4. Contract information
5. Trade execution
6. Transaction data
7. Timestamp information
8. Others

Reporting time

T+2, two business days after the trade is executed.

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