Episode Transcript
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Andrew Keith Walker (00:10):
Hi, I'm
Andrew Keith Walker.
Barbara Ruiz Alonso (00:12):
Hello, I'm
Barbara Ruiz Hi, I'm Laura
Rodriguez.
Laura Rodriguez (00:15):
Hi, I'm John.
Andrew Keith Walker (00:15):
Curden.
Hi, I'm Nick Bruce and this isthe number one regulatory
reporting podcast in the EU, theUK and around the world.
So join us as we go behind thescenes and under the hood to
look at the big issues and newsstories, companies and
personalities who are shapingthe world of Rektech, fintech
and trade repositories.
Welcome to the Registr Roundup.
(00:36):
And remember, this podcast isbrought to you by Registr, which
is a six company and featuresmembers of the Registr team and
special guests offering theirpersonal opinions, not the
opinions of Registr as anorganisation.
There is no representation madeas to the accuracy or
completeness of information inthis podcast, nor should you
take it as legal, tax or otherprofessional advice.
(00:58):
And welcome back to the RegistrRoundup, first show of the year
.
Yes, thank you, we are back.
We are back.
All right, calm down, don't gettoo excited.
(01:18):
We are back and it is oneawesome year ahead, because
there's a whole bunch ofregulations kicking in, but all
eyes are on the deadline, 29thof April, and a mere refits.
We've been building up to thisfor a long time.
We know that you have to.
So this show, we are going tobe getting everything organised.
We are getting rid of thewrapping paper and the half
(01:39):
eaten Terry's chocolate orangeand we are getting our desks
organised for what is going tobe a really busy few months
coming up, and it is happeninghere in the virtual studio.
We have the full team back inthe virtual studio, most of them
struck down with this nastycold that is going around
Wherever you are in Europe.
It seems that you've alsoprobably got that same thing
(02:01):
that happens every year.
You work really really hardright up to Christmas, then you
take a break, you eat someturkey and the next thing you
know you've got the flu.
Still, we are all back in thestudio, slightly gruff, some of
us coughing, some of us sneezing, in no particular order, but
starting with the nicest andmost efficient person in the
organisation, back for 2024,barbara Ruiz Alonso, head of
(02:22):
Client Services.
Barbara, welcome back.
John Kernan (02:24):
Thank you, andrew.
Hello everyone, happy New Year,happy 2024.
Really looking forward for thisexciting year ahead and happy
to be back in my favouritepodcast.
Andrew Keith Walker (02:36):
It's good
to have you back, barbara.
Joining Barbara, of course, isher Spanish compatriot, the
pride of Spain herself, ofcourse, with a special starring
role.
Today, she takes us throughESMA's work plan for 2024.
It is the head of InstitutionalRelations, lara Rodriguez.
Lara, welcome back.
Barbara Ruiz Alonso (02:56):
Hi Andrew.
Thank you very much.
Feliz Páñol to everyone.
Very exciting news andinformation for this year.
As you said at the beginning,let's discuss a little bit about
it today.
Andrew Keith Walker (03:11):
Joining
Barbara and Lara in the studio.
Of course it's the man who usedto put the canary in the wharf.
Then he was in Devonshire andNever Square.
Now he looks after St Mary'sAxe.
It is the CEO of Registria inthe UK Arvarium, sir John Kern.
And John, welcome back.
Laura Rodriguez (03:28):
Thanks, andrew.
Happy New Year, everyone.
Great to be back this week.
Actually is the anniversary of10 years of Devon Registria.
Andrew Keith Walker (03:37):
That's good
.
So, john, 10 years it's amazingyou actually look younger now
than you did when you joined.
Laura Rodriguez (03:42):
I must have
been in terrible shape when I
joined that Andrew.
John Kernan (03:46):
I agree with Andrew
.
You look the same, I will say,and that's absolutely true.
Laura Rodriguez (03:52):
Thanks guys,
I'll send you the money later.
Nick Bruce (03:56):
What's gone wrong
with me then?
Andrew Keith Walker (03:58):
There is
nothing wrong with you, and that
is, of course, the voice of ourvery own voice of reason.
The head of businessdevelopment for Registry,
armistress Nicholas Bruce.
Nick, welcome back.
Nick Bruce (04:08):
Thank you, andrew,
and happy New Year everyone.
Andrew Keith Walker (04:10):
Let's get
moving with what is going to be
a very busy show this week,because we have a lot to get
through, and we're going tostart by coming over to our head
of institutional relations,laura Rodriguez, and asking you
about the big news ESMA's 2024work plan.
This is a big deal for thesecurities lending industry, for
(04:33):
the repo industry, for TRs, formarket participants, because it
outlines where the focus isgoing to be this year for
hands-on changes,implementations, white papers,
new focus for ESMA after a mereall that stuff.
So why don't you break it downfor us and take us through the
(04:53):
big picture there?
Barbara Ruiz Alonso (04:54):
Okay, great
, let's do it.
Yes, you know, this year wehave been very focused on the TR
side, on EME refit, but thereare so much more.
This paper, this work program,includes so many additional
legislative projects that ESMAand the rest of the EO
(05:14):
authorities will be working onto keep them busy and to keep us
busy during the next year and,of course, for all the financial
markets.
There will be a lot of upcomingnew challenges.
I will quickly mention, justdue to the relevance that it
(05:37):
will have, the activitiesregarding sustainable finance.
So here ESMA will deliver itsfinal report on greenwashing.
We also discussed this in thelast podcast, but, just for
everyone that is interested inthis ESG project, they should
definitely look into this onESMA website in the coming
(06:00):
months.
And I want you to get into thediscussion of the main key
drivers for ESMA, which areconvergence one of them, of
course, digital finance, mainlyto facilitate the technology
innovation for the effective useof the data, which is what all
(06:21):
authorities are now looking forthe entities to be able to use
properly the data, and also forthemselves, for their
supervisory activities.
So, looking at the convergenceside, we solicit guidance and
tools for the supervisoryconvergence on MIFIR, on MIFIT 2
, on search selling regulationand on EMEA.
(06:43):
Of course, and looking at thetechnology innovation, ESMA will
issue technical standards forthe European single access point
.
So the European single accesspoint is a critical project for
ESMA where they want to providefree and centralized access to
financial andsustainability-related
(07:05):
information about the EUcompanies and all the EU
investment entities andinvestment products.
This huge project is expected tobecome operational in July 2026
, so still a lot of work to doand many consultation papers to
come.
Actually, there is now one openon ESMA website for those
(07:28):
interested and in thisconsultation paper they have
started to define the task ofthe technical standards that the
data collection bodies whichwill be ESMA, EBA supervisory
bodies, which technicalstandards they sell apply to
validate whether the informationsubmitted by the entities
(07:52):
comply with the specificationswith this regulation and then to
make this information publiclyavailable.
So this really took myattention.
On the report, this singleaccess point and the words that
will come here, the PRs we won'thave much impact on this, but
(08:15):
of course it will be mainly theentities that already have
regulatory reports inobligations which will be
impacted.
So again, everyone that isinterested, they should go now
to ESMA website, look into thisand see to which extent they
will be obliged to commit or tocomply with this reporting
(08:37):
obligation to make thisinformation available to ESMA.
Andrew Keith Walker (08:41):
Now let's
talk about technical standards
documentation, because there isactually technical standards
coming for Micah and Dora thisyear, as well as technical
standards for Mithrid and Mafiathat will be coming out.
What's that going to mean fordata quality, data harmonization
, all those usual topics thatseem to revolve around the
(09:01):
publication of technicalstandards?
Barbara Ruiz Alonso (09:04):
Yes.
So, as I said, what ESMA islooking here mainly is
convergence.
So they will try to adapt orupdate these technical standards
in the way to make it convergewith all the different
regulations that they have nowin the market, so there are not
(09:25):
inconsistencies and thedifferent entities can comply
easily with all of them withoutmany dependencies or
inconsistencies between them.
Andrew Keith Walker (09:38):
Okay, good,
and on that topic as well,
there is going to be an impacton TRs from all of this.
Isn't there?
Because this is all feedinginto AMIR's data quality report,
which will also be coming outsoon, and that's going to be
quite important becauseobviously the data quality
report affects the way that theyfinalize technical standards.
(10:00):
So what can we expect from that?
When's the data quality reportout and what do you think is
going to be the big news in that?
Are you willing to make aprediction?
Barbara Ruiz Alonso (10:10):
A
prediction on when they are
going to publish it in thecontext?
I'm not that sure, but yes, asevery year, sma will issue this
data quality report as a peerreview and follow up on the
previous ones.
There will be severalactivities on data quality in
(10:31):
general for the TRs, for amirror and SFTR data.
The TRs we sell expect a followup on several projects that SMA
started last year or two yearsago with the aims to improve the
data and to identify stillinconsistencies that might be
(10:53):
between the regulation and thefinal implementations, also in
the views of Amy Refit.
This year data quality reportwill be based on last year data
2023.
It will be very interesting tosee also the difference between
(11:16):
this report that will come thisyear and the next one, which
will be based on Amy Refit.
We will really see otherchallenges that the data will
suffer with the implementationof Amy Refit.
Very interesting to look to thisupcoming report that might be
(11:38):
published probably in April-May.
It's when SMA usually publishthis information.
Also, with the implementationof Amy Refit, we don't know to
which extent its timelines willchange, but more or less it will
be meet this year.
Of course, one of the pointsthat we are expecting still from
(12:01):
SMA.
The TRs are the revision of theEMEAR public data requirements.
This is still pending on SMAsite to be published.
It's something that TRs.
We need this guidance tofulfill the obligations on
public data for Amy Refit which,as I said, we still don't know
(12:25):
really what will be the approachfor Amy Refit.
We don't know if it will keepthe same that we have right now
or there will be changes, butit's a public consideration that
it will come in the next months.
Andrew Keith Walker (12:40):
Tell us a
bit more about the peer review
process, because this isn'tsomething we never really go
into that much depth about thesetechnical issues, but it's a
really interesting area to getinto because, of course, there's
peer reviews on the Europeanside and I'm guessing there must
be some peer review processthat also affects the UK.
But, laura, starting with you,tell us a bit more about the
(13:02):
peer review process, becausethis is going to be important,
isn't it for TRs, because thisis where a lot of the assessment
of data comes from as well.
Barbara Ruiz Alonso (13:11):
Yeah,
absolutely so.
Peer reviews are reallyimportant.
It's a tool for supervisoryconvergence and also because it
gives ESMA the big picture well,not ESMA the full market.
They gave us the big picture ofthe consistency and the
effectiveness of NCA in theirsupervisory practice.
(13:34):
So this year and next yearthere will be very interesting
peer reviews published on theEuropean side.
So, for example, one that ESMApublished years ago in 2022, it
was a peer review to ensure thesupervision of cross-border
(13:58):
activities.
So this year, esma will assessagain whether the NCA's have
sufficiently if they havesufficiently improved their
supervision across theircross-border activities.
Let's say that is kind of anexam to see if the NCA's has to
(14:19):
be properly using theirsupervisory tools and the
regulation that is in play fortheir activities for their
supervisory purposes.
So this peer review will comethis year to assess this
effectiveness of the NCA'sactivities and, yeah, I'm really
(14:44):
looking forward to know alittle bit more about this one.
And, of course, there are manyother peer reviews coming the
one that we just discussed ondata quality.
There will be a peer reviewthat is now annually for CCPs,
where ESMA analyzed thesupervision of the new CCPs, and
(15:09):
this year it will be mainlyabout the CCPs, outsourcing an
intragroup governancearrangement, so really
interesting.
Probably we will see thatcoming in a future also for
trade repositories.
But it's true that now the peerreview is focused on these CCPs
(15:30):
and well, additional peerreviews that will come are
related with implementation ofthe requirements of
securitization regulation somany different regulations that
ESMA has put in place.
Now they are doing this peerreview to see to which extent
they are properly enforced.
(15:50):
So at least on the scope forthe European regulation they are
trying to see thiseffectiveness and it's great to
see the results.
Andrew Keith Walker (16:04):
Now, John,
obviously you don't have peer
review processes in the same wayhere in the UK, but there is
some sort of angle to thisthat's going to be interesting
from your perspective.
Laura Rodriguez (16:16):
The dynamic in
the UK is different because
obviously you don't havemultiple national competent
authorities and then an ESMAtype entity kind of supervising
the market infrastructures ontop of that.
So I dare say the output thatthe peer reviews taking place
within the European Union willbe very informative for the UK,
(16:43):
but obviously it's a differentdynamic from a regulatory
perspective.
Nick Bruce (16:48):
I mean the FCA can't
do it, but they're obviously,
you'd imagine they will watchthe output that's published by
ESMA for their own internalreview processes.
Yeah, I think this is exactlyright.
I think Wales they would do.
John Kernan (16:59):
Yeah, so the levels
of the European NTAs.
They will see how good or badthey are doing themselves.
Andrew Keith Walker (17:05):
Okay, and
so, Laura, I'm interested.
Let's now we've looked at whatAmir are going to be doing for
the year.
I want to come around each ofyour departments and find out
what you're going to be doingfor the year because, of course,
traditionally January is thattime when your budget's open up,
your plan's get into place andyou've got that long view of the
(17:26):
milestones you want to hit.
Now I want to come to you,Laura, because, of course, your
relations, all eyes have been onAmir for so long.
You must now be starting tofocus on the next set of speed
bumps that are coming this way,as they always do in regulatory
reporting.
Barbara Ruiz Alonso (17:42):
Yes, very
interesting question, because
there are so many activities forthis year that I don't really
know which one to, but I willtry.
I will say that one of the coreactivities that we will do
regarding Amir Refit will berelated with the access to data
for authorities.
So Amir Refit is changing alsothe way authorities access the
(18:07):
data of the TRs, so we need toadapt the access that they have
currently now under Amir.
We will have to adapt it to thenew access through Amir Refit.
This is a very sensitiveexercise and very important
(18:28):
because we need to ensure thatwe will provide correctly the
data to the authority under thenew requirements.
So this is a big exercise thatwe are doing internally and that
we have already started sharingwith the authorities for having
their agreement and finalizeall the additional paperwork,
(18:54):
let's say, new accounts, newaccess, etc.
And this will keep us reallybusy until the implementation of
Amir Refit, because there aremany authorities.
We have around almost 50authorities, each one of them
with different access andaccessing, of course, and
(19:17):
supervising differentjurisdictions.
So, yeah, it is a reallyrelevant and interesting
exercise to complete and on theother side, we will have a lot
of work related withconsultation papers.
As you know, we have a full yearof review of technical
(19:41):
standards and consultationpapers under Dora regulation.
It seems far away fromimplementation because it is
January 2025, but it is not thatfar because in this year we
have consultation papers thatare now open for the draft
technical standards.
We will have now in January, oris expected in January, the
(20:06):
final report of a drafttechnical standards that were
already published last year.
So, yeah, dora is going to keepus very busy and, in addition
to Dora, one importantconsultation paper that will
come also this year is relatedwith the new guidance, or
(20:29):
guidance that ESMA wants toprovide to the TDRs regarding
governance.
So here ESMA is increasing,putting more pressure on the
TDRs and their supervisoryactivities by indicating the way
(20:49):
entities or financialinfrastructure, as trade reports
, has to govern and how theirgovernment bodies has to be.
So it's going to be a verychallenging consultation for
this year and, yeah, I thinkthis, I will highlight these
(21:13):
three aspects, let's say butyeah, mid-year we can review.
John Kernan (21:20):
So it seems it's
not only a tough year for
participants, also for NTAs, forthe TDRs themselves.
It's going to be a great 2024.
Andrew Keith Walker (21:31):
I can see
that.
I saw that as I was readingthrough.
One of the things it mentionedwhich sounds a bit ominous is
stress tests for tier two CCPs,which that sounds like it's
going to be fun for them.
Is there anything else youthink in ESMA's report that's
maybe beyond the world of TDRsbut you think it's going to
cause big ripples with theirwork plan for market
(21:55):
participants?
Barbara Ruiz Alonso (21:57):
Well, all
related with digital finance,
new technical standards andguidelines on MICA regulations.
There will be also the firstannual report under the DLT
pilot regime, which would bevery interesting to look at it
when it's published and whilelooking into a different sector
(22:19):
that ESMA is supervising, let'ssay, or adding information, a
lot of different information oninvestment management, the
credit rating agencies.
Of course, they will have alsoa lot of activities on the
supervisory activities that ESMAhas with them Data reporting
(22:42):
service providers too, witheverybody's RTSS.
I mean.
So many information we havehere, of course, discuss what we
have seen, the more interestingones and the more relevant ones
for us, but there are manydifferent activities that ESMA
is working, yeah, and we'reabout a year full of challenges,
(23:09):
let's say, and I would like toadd now out of the scope of the
ESMA report, and something thatis also impacting us and will
impact the reportingrequirements under the
Switzerland regime.
As you know, this year we willstart the FinFRAC review, the
(23:29):
developments on the SwissFinancial Market Infrastructure
Act, we call FinFRAC, which, ofcourse, is a regulation which
has specific requirements thatare working well.
The regulation is on track,let's say, but there is always
opportunities for improvementand that's something that the
(23:52):
supervisor authority, finma,will start to explore this year
with consultation papers toadapt this regulation, and we
will be also very lookingforward to have what they want
to change, what they want tostrengthen in this regime.
(24:14):
And, of course, we will bethere to comment on the
different activities that theywant to adapt.
Laura Rodriguez (24:24):
I guess that
was maybe to be expected after
the Credit Suisse UBS situationas well.
Barbara Ruiz Alonso (24:30):
Yes,
exactly For sure.
They will take everything intoaccount and, as I said, the
regulation is on track, but ofcourse it's a much simpler
regulation that we have in theUK.
I don't think they want tochange it that much, to make it
(24:51):
extremely complex, but probablythey will have identified
specific deficiencies and it'ssomething that they will raise
and change.
Andrew Keith Walker (25:02):
Nick, what
about yourself?
What's your desk looking like?
Have you got it nice and tidy?
Have you got your plannerorganised?
You can see exactly whereyou're going, or is it a massive
heap of paper that just keepsgetting higher and higher for
2024?
Nick Bruce (25:16):
Okay.
Well, it's mainly electronicnow, so at least we haven't got
the paper burden.
But I guess the way I look atit is I'm probably like every
other team leader in everycompany around the world is that
I've got three buckets, I guess.
So the first one is what I'dlike to do, then there's why I
should do and then there's why Ican do.
(25:38):
So I think when you just listento Laura and everything Laura
is talking about, I think youcan probably understand that
there's two buckets.
I'm just putting it outside theback door so I'm not going to
get to them.
So I think very much what we'relooking at for 2024 is around
the can do, because, certainlyfor me, there's a lot of stuff
(25:58):
that's entrained, that's goingto be coming down the line, but
the immediate focus has to bearound the near and around the
rewrite, because that's what'sgoing to impact our clients the
most over the next six months.
Really, it's going to be thenext 12 months and there's a lot
of immediate actions that weneed to be taking.
It's actually quite hard tothink past those, because we're
(26:21):
going to see that there's aconstant need to adapt and
adjust as Mia goes live.
But what we're looking at themoment really from my side is
there's a number of things we'redoing.
We're looking at our website asa collective and we're updating
our website at the moment toincrease the refit tools that we
have on it, and a lot of thatis around the fact that we
(26:42):
mentioned it previously.
We still have the vast majorityof our clients that are looking
at refit as a Q1 developmentfor this year, so really they're
only now in earnest puttingtheir teams together and looking
to build the platform and starttesting with us.
So what we're looking to do isto make sure that we've got the
tools so that clients canactually go onto our website and
(27:04):
empower themselves, because youknow, resources are finite and
that's on our side as well, soit's to allow clients to easily
access the right resources tofurther their programs and to
assist themselves.
Around that, we're also settingup further webinars.
We talked about webinars, somonthly webinars until go live
(27:24):
date.
Also, my team are workingdirectly with their client bases
and talking to their clientsand supporting our clients
around refit as well, and we'refeeding that all back into the
wider collective in terms ofwhat we need to be doing and
just intelligence sharing.
We're also you know nothing thatI can talk about more publicly
(27:45):
at the moment, but I'm alsotalking to a number of our
partners, because I'm also.
What I appreciate is the factthat a lot of our clients are
going to need help andassistance To get over the line
and as a trade repository,obviously we're quite restricted
in what we can and what wecan't do.
So we're working with a numberof our clients and with a number
of our partners to ensure that,if we can, we can introduce
(28:08):
them to the right resources tohelp them with their programs.
So it's really going to bethat's just January, so it's
going to be a really busy kindof quarter to ensure that our
clients are where they need tobe, so that they're all ready
for go live date.
And you know, thinking past thatat the moment it's.
You know, I'd love to, but Ithink we just have to think
(28:29):
about the here and now.
I just make sure that all ofour resources are freed up so
they can focus on that andprovide the right level of
support, and I'm guessingBarbara is probably going to say
things along the same lines aswell.
Andrew Keith Walker (28:41):
In a way
we've all been here before.
We remember SFTR, the Good OldDays.
That was seems like a lifetimeago when we first started the
show, but of course SFTR issignificantly smaller.
So are you basically aware ofall the potential issues that
are going to hit after the April29th deadline and just need to
be braced for a lot more scaleand volume to deal with?
(29:05):
When it comes to the kind ofconversations you'll be having,
kind of requests you'll begetting from clients, the kind
of problems they're going to becoming to you and to potentially
to partners to talk about.
Nick Bruce (29:19):
Yeah, that's a
really good question.
And I again talking to buckets.
I think this time of the yearagain, there's two buckets when
it comes to scales.
The first one is the scales Istep on to measure my weight and
at this time of the yearthey're definitely going out the
back door because I do not wantto know any resolution.
I've got around exercise.
That's going out the back dooras well because that's not going
to happen.
(29:40):
But in terms of the, when welook at mere reporting, the
scale of this and the impact ofthis across market participants,
you know we're talking.
You know this is more thanfourfold.
We've got 1600 or more than1600 clients.
When you look at the EU, over50% of all derivative
transactions are reportedthrough us.
(30:01):
This is absolutely massive interms of the scale.
And I think the problem is it'snot so much what we know, it's
we know we're going to have thisfallout.
We know about the increasingfields, we know about the focus
on reconciliations and there'sgoing to be initial teething
problems.
We know that.
We just don't know what theywill be and that's the problem
(30:22):
is staffing and scaling up andfreeing up resources for
something where we don't knowwhere the issues are.
But we know that there is goingto be a lot of work involved.
There's going to be a lot ofhand holding after go live.
But, barbara, I know youprobably got some more thoughts
on this as well.
John Kernan (30:35):
Well, I mean
absolutely in line with what
you're saying, and for me, thekey point is SXTR was new.
At the time there was no dataon it, so we had a new system
and it had things that workedfrom the beginning, things that
we well, we had to improve overthe following months.
But Emir already exists and, asNick is saying, it has a huge
(30:58):
amount of data.
So most of the challenges aheadare making sure all the legacy
data is updated and it keeps theflow it needs to keep in terms
of reconciliation, lifecycleevents, updates.
Everyone needs to be aligned.
So again, going back to Nickcomments that some of the
(31:21):
participants are yet not readyor are only now starting to
gather the teams.
This is not easy and I'm sorryto be panicking.
I don't mean to, you know,raise to make anyone panic.
Still, you have time.
But talking about scaling thedesk, on our side, it's already
(31:42):
receiving a increasing amount ofemails every day.
So we see from the new year andalso the end of last year that
those teams are waking.
People are starting to talk, toinvestigate, to discuss, to
learn what they have to do, andwe're only four months ahead of
(32:04):
the reporting start date and I'msure everyone at some point
will realize that testing,developing, talking to partners,
to developers, whatever it'snot something you can do from
one day to the other.
So, again, I would recommend tostart today, start testing,
start requesting us yourcredentials.
(32:25):
Also, in line of what Nick issaying, the webinars that we
will be doing will be monthly.
Now, in the next weeks, we willdo one focusing on walking
through the CSV to XML converter, and also we are planning one
dedicated to the recontiliationprocess that we know most of our
(32:47):
clients are really worriedabout that, but we keep
progressing and also now we'restarting.
There's more coming every week,every month.
Our developers, our testers arefully dedicated to new things.
So it's good that participantsstart now, because it is tough.
(33:07):
I'm sorry to say it, but it istough.
Nick Bruce (33:10):
Even from our side.
Where's the people asking what'sthe key focus?
And when we look at the UAT, aswe've always said, it's
constantly evolving, and that'spart of the web analysis that we
constantly talk through, thatwe talk about new functionality,
and the focus now is obviouslyensuring that clients can test
and do end-to-end testing, andit's also happened to make the
adaptations, as we have had someslight schema changes, which
(33:33):
obviously impacts us as well.
The next evolution, then, is thevalue added side, where it's
things like the benchmarkingdata, so the clients can start
looking at their data quality,they can understand the type of
reporting that they're going tobe receiving from us.
But again, I can't keep askingme about these kind of aspects,
but the focus at the moment hasto be on the ear and now, in
(33:55):
terms of the immediacy, is let'sget testing, let's make sure
all the tools are there for theend-to-end, and then we can then
focus on dropping that soclients can get to groups before
it goes live, so, again, theycan actually start to see the
tools that they'll have, thebenefits that they'll be able to
offer once we go forward intorefit.
And again, it's all aboutempowering clients.
I mean, they're going to besurprised when they see going
(34:18):
forward how much they're goingto have sort of at their
fingertips compared to what theyhave today, which is a real
positive.
John Kernan (34:24):
To me, it is also
about making the right decisions
.
So clients will have to makesure if they want to keep
following the same regime, thesame roles that they are doing
now, if they are reportingthemselves their own obligations
or if they are delegating, ifthey want to be more a watcher,
(34:45):
meaning they delegate thereporting and they just receive
data.
We also have that role withrefit, because maybe some of our
clients are already late by thetime they start in realizing
the changes they have to apply.
They will realize it's not onlyokay, I don't have time to do
this, I have to delegate to athird party.
That also means changes with usin terms of onboarding or new
(35:09):
documentation you have toprovide, and with EMEA I
remember.
So we talked about the 10th yearanniversary of June.
Before my 10th year anniversary, I think I mentioned this on
the last podcast.
It was in October 2023.
And I really remember when Istarted at Registria right a few
(35:29):
months before the reportingstarted, the pile of paper of
new contracts the week before wewent live was up my size.
Really, it was unbelievable.
We had every single person inthe company opening accounts and
we couldn't even open all ofthem because many of the
(35:50):
participants just realized abouttheir obligations really a few
days before that.
So again, I hope that doesn'thappen again because we cannot
guarantee obviously we canonboard everyone at the same
time.
We are working on a very modernwebsite and tools so they can
onboard themselves and clientscan do a lot of the things
(36:12):
themselves.
But still we have to doourselves a check, we have to do
checks, we have to verify theiraccess and everything, and that
takes time.
So please also benefit of ourweekends and our nights at work.
Do it with time, because againthese things happen and I really
(36:33):
remember those days eatingpizza here at night because we
had to onboard a thousandclients in a week.
Laura Rodriguez (36:41):
I can remember
that well, barbara.
It was something like 80% ofour client base came in the last
four weeks before reportingstart date.
It was absolutely mayhem.
So, yeah, that's to be avoidedif at all possible.
From a UK perspective, I supposeI'm also looking at things this
year from a three prongedapproach.
(37:02):
One is kind of BAU orhousekeeping Although I probably
shouldn't call it housekeepingbecause it's much more important
than housekeeping would implybut that is things like
following up on action pointsfrom our ongoing compliance work
(37:22):
program in turn, all of thisstuff to make sure that we
remain robust.
So there's a lot of activitygoing on there.
Also, things like the FCA's TRportfolio letter.
There are a number of itemsthere.
There are a number of itemsthere that we're already doing,
but we need to continue tomonitor their development and
(37:44):
progress and report back on that, and that's really far ranging.
So it goes from things likedemonstrating value for money so
things like the clientsatisfaction survey that we did
last year we went through to howyou monitor your outsourcing
and things like that.
So there's one element.
The second element, obviously,is refit as well.
(38:07):
Of course, we have the luxury,if I can put it that way, of an
extra five months in the UK.
But I can echo what the guyshave said.
One of the most fundamentalthings for us is to continue to
support our clients with refitinformation.
They've mentioned the workinggroups, etc.
Which will also be a benefit toUK clients.
(38:30):
One of the things we willcertainly do next year is rerun
the refit.
Last year it was a breakfastbriefing.
Maybe we'll do the same againand this year, by the point
being, we will do that post-EUimplementation.
So it's almost like post mortem.
(38:52):
Maybe that's also not theappropriate way to describe it,
but you know what I mean.
We'll be able to give feedbackon lessons learned with actual
production data, and I thinkthat will be invaluable for UK
clients.
Andrew Keith Walker (39:09):
Naturally,
the idea that sort of springs
into my head is yeah, but surelyif you've got any trades at all
that are open and ongoing withEU partners, you're going to
have all your ducks in a rowalready, because they will
already be reporting way beforeyou.
So do you think UK participantsare really going to be using
that five months effectively, orare they going to have
(39:30):
everything lined up already?
Laura Rodriguez (39:32):
I think it
depends on what sort of
participant you are.
I mean, don't forget, we have avery diverse client base as
well, from tier one banks tocorporate treasurers, so they're
not necessarily allcross-jurisdictional clients,
they're not necessarily tradingwith cross-jurisdictional
entities.
I think it depends what sort ofclients you are.
Obviously the vast majority ofour volume comes from our bigger
(39:57):
tier one clients, that'sprobably obvious.
And for those clients they willhave gone through EU refit.
But also we shouldn't fall intothe trap in just assuming that
the UK implementation will be afacsimile of the EU.
There are FCA refit workinggroups that are well underway
(40:21):
and will continue for the nextcouple of months.
From that, q&a's will evolveetc.
And there may be some degree ofdivergence, although, as we've
said before, we don't expect itto be significant as the FCA
themselves.
We're somehow one of thearchitects of refit back in the
day.
(40:42):
And then I suppose the thirdpillar Nick will be happy to
hear the third pillar is to growthe business.
The way I see it, with theimplementation of refit you've
got the ISO 2082 standard.
That makes portability mucheasier.
I also think with some of theonerous requirements from refit
(41:05):
itself surrounding exceptionmanagement, errors and emissions
reporting, all that kind ofstuff, and this is for you,
barbara.
I think that's going to makeservice support from your TR
even more fundamental than it istoday and, from where I sit, I
think that presents a greatopportunity for Registria UK to
grow our client base.
Andrew Keith Walker (41:26):
Well, on
that very front, Barbara, we
come finally to you, head ofclient services, ultimately
there by the phone, where thewhole team of people that got a
big box of tissues for clientswho are having a crisis.
You've already said that.
You know you're expectingvolumes to be challenging.
You're seeing that ramping up.
(41:46):
Do you get a chance to actuallyplan for the year or do you
have to basically be there witha fire extinguisher and, you
know, hope for the best?
John Kernan (41:56):
I try to plan, I
always try to plan.
I have my diary with me.
I have this as a person, theChristmas person that's for
people who are listening.
Andrew Keith Walker (42:05):
By the way,
Barbara has just held up a book
that is the size of anencyclopedia.
That is a big diary, Barbara.
That is a very big diaryBecause there are many things to
plan.
John Kernan (42:14):
There are many
things to plan Not only because
I have a big family now, butalso because 2024, I mean it's
been the whole podcast aboutwhat's to come.
I think it's no secret thatthere's a lot on everyone's
plate.
We do try to plan.
I'm kind of maniacic here let'ssay trying to stick to the plan
(42:39):
, although of course theextinguisher will be needed for
sure At some point.
This is what I'm trying toavoid trying to make awareness
to everyone listening.
The more we plan, the more timewe do this, it will be easier
for everyone.
Yeah, the help desk is gettingbusier every day.
(43:04):
Also, a refit is being plannedexhaustively.
We're trying to deliver everynew development with the highest
of the qualities.
Also for clients that arealready testing that it looks
like no one is testing now.
We have many clients that arealready supporting us a lot on
(43:27):
fine tuning the tool.
By the end of this month, ourclients may expect to have a
margin state end of the reports,which are very important for
most of our participants.
We will be also performingreconciliation by the end of
January.
At this stage, clients will beable to query the outcome of the
(43:49):
reconciliation process,searching it from our website
with something similar to oursearch and functionality for the
trade activity or the tradestate.
This is very important becausemany of the questions we were
receiving before at the helpdesk was about data quality.
Again, it all goes like a cycle.
(44:10):
Esma is very worried aboutreconciliation.
That means NCHR and it meansour participants are worried.
This new tool will empowerclients again to realize where
are their weaknesses, with whatparticipants they have worst
reconciliation rates.
That's the target of the wholerelease we are planning for this
(44:35):
month.
Also, after that, other reportswill come, especially with the
outliers and some enhancement tothe reconciliation.
More since we report dataaccess functionality also very
valuable for clients morereporting statistics Actually,
the whole thing is being planned.
(44:57):
Clients have all the visibility.
The first, let's say M-year 1.0, what we had so far, or M-year
2.0, because we had the RTSS in2017.
Now I think we really learnedfrom the past.
The tool clients will see it isfar improved from what we have
(45:20):
currently.
I hope they like it.
I hope they use it.
Of course, I want to keep myrole and my team, but I think
they will be more independentand they won't be so dependent
on our feedback and on oursupport.
Barbara Ruiz Alonso (45:38):
Actually,
Barbara, to continue to raise
the awareness that you wanted onthe client side, just wanted to
comment that authorities arealso asking us what is the
readiness of our clients.
They are really interested toknow if they are using our tools
, if they are ready to test,meaning that they have
(45:59):
everything ready and on track.
Of course, it's an update thatwe are sharing with them.
What is the status of our UATenvironment?
Just to let you know thatauthorities are also asking us
on client readiness.
Andrew Keith Walker (46:22):
Okay, good,
so everyone, it's all lies on
you again, barbara.
What can we say?
You know Laura's job is done,yours is going to get very, very
busy.
And John, you've got a fivemonths lie in lucky for you, and
Nick not not so lucky for you.
You're going to be busy first,but I'm guessing you then get
(46:45):
the opportunity to pull a hugeamount of knowledge and
expertise together within theRegistry R teams to make these
transitions happen smoother forclients.
The thing that I'm findingquite difficult to take on board
here is that are there reallythat many clients who haven't
got their head around a mererefit yet, because we've been
(47:07):
talking about it for two yearsnow?
Laura Rodriguez (47:10):
Yeah, I mean
that's basically the thing you
need to consider as well, Andrew.
I mean we talked before aboutcross-jurisdictional clients,
but they're regularly regulatoryrewrites going on across the
globe at the moment.
So you know, refit is nothappening in isolation and if
you're a tier one bank, you'vebeen working on the CFTC
rewrites etc.
Etc.
So it's a question of bandwidth.
Even even for those hugeinternational entities it's a
(47:33):
question of bandwidth and it'svery niche expertise as well.
So it's very difficult to justscale up a project team, you
know, with the commensuratelevel of expertise required for,
for Reg, reporting.
Nick Bruce (47:49):
Yeah, I think that's
a really good point, john.
You know and there's adifference as well between you
know different entities, though,if you're talking about a tier
one bank, even if they haven'tbeen tested yet, they have a big
pool of resources that they caneasily reallocate, and these
are experienced resources thatare already working on the other
(48:09):
rewrites, so for those teams tocome in and execute a short
period of time is far easier.
So sometimes it's very, veryhard to say are people that
aren't even testing with us andnot ready yet.
The fact they're not testingwith us doesn't mean that they
haven't, and most of them have.
The ones I'm speaking to,they've done the analysis,
they've done the gap analysis,they've been working on their
(48:29):
data vendors.
The thing for them is it's aboutallocation, it's about cost, so
, but all of these guys, theirprojects for last year, they
needed to secure the funding,probably by the end of the
summer in 2022.
And that just wasn't possible.
So it comes down to a fundingquestion.
So I think a lot of thegroundwork has been done, but
for these guys now it's aboutgoing into execution mode, and
(48:53):
that's where I'm with Barbara inthe fact that what you don't
want is this being a kind of abunfight for resources all at
the last minute, and then peoplehaving to react and change
maybe the structure in what theydo for an interim period and
then actually looking at it andthen having to go.
Well, actually it's not theoptimum model because of things
(49:13):
like the errors, emissionsreporting, the oversight, etc.
And my worry is that you'regoing to see people taking
decisions just for the need tomeet the criteria come April
29th and then realizing thatthey need still to then move to
an optimum model, whereas thebest thing for them is to have a
(49:33):
good, easy path to develop thatmodel from day one.
But I think these are the kindof things we're going to work
with clients to meet to beperfectly honest, and that's
where I've got my concerns.
Andrew Keith Walker (49:44):
So it is a
big year.
I think we can all agree onthat.
It's going to be a big year.
It's going to be a big fewmonths, and as we cough and
splutter through this verychallenging time and I'm sure
you are too, if you're back atwork already I'm sure it hasn't
been easy Don't get in the liftwith anyone.
As my advice and on that frontwe do need to ask a few
questions, don't we?
About your new year'sresolutions?
(50:06):
Yes, it is a new year andtraditionally we like to ask the
Registry team just what they'vegot planned.
So I'm going to come around,each of you in turn, and find
out what your new year'sresolution is going to be,
starting, of course, with you,john.
What have you got in mind?
Laura Rodriguez (50:23):
Do you know
what?
I do have a couple of newyear's resolutions, but I'm
sorry to say that neither ofthem I'm prepared to repeat in
public.
So Okay, I guess what I need todo is to have another crack at
giving up smoking.
I gave up smoking last Aprilwhen I hit 50.
And yeah, for maybe I don'tknow four or five months and
(50:47):
then yeah, so I need to givethat another serious go.
Andrew Keith Walker (50:52):
Well, you
know I'm going to say now I
think we should all be verypositive.
You gave up for four or fivemonths.
That's fantastic news, welldone.
Nick Bruce (51:01):
Oh, thanks man.
Andrew Keith Walker (51:02):
I think
that's absolutely brilliant.
It's a very.
I was there myself 12 years ago, you know, when I turned 40,
facing it.
It's a massive challenge, I'mgoing to say.
Arguably it's harder than youknow reconciling an extra 100 or
so fields of data with acounterparty on the other side
of the world than it is to.
(51:23):
You know, lay off thatpernicious weed.
So well done, john, on thatfront.
Keep going, keep going.
Encouragement, we're having apositive session Talking
positive things.
Barbara, what about yourself?
John Kernan (51:36):
Not sure it's
really positive.
But honestly, andrew, my newyears of solution, it's survived
, that's this year.
I cannot afford anythingfurther than that with my three
kids between zero and five yearsold, all the flus that are
coming to my house, Refit,survival, it's also a challenge.
(51:59):
And then my age.
I guess I told my husband if wesurvive this year, if we're
three super small kids, thenwe're good.
So survival, that's like thebig line.
Andrew Keith Walker (52:10):
Well, I
can't tell you how much we all
want you to survive too, barbaraas well.
But the thing is you've got tolook on the bright side again.
I'm going to say you know, withthree children under five, then
you're almost certainly goingto have an amazing immune system
.
At the end of that, you'll bethe only person who doesn't get
a cold next Christmas becauseyou'll have had them all.
John Kernan (52:27):
I got vaccinated.
I got vaccinated of everythingI could.
Andrew Keith Walker (52:31):
to be
honest, Laura, are you going to
be going around and injectingany national competent
authorities with a little bit ofthe mica vaccine?
Barbara Ruiz Alonso (52:41):
Actually, I
always have a huge list of
resolutions, but I will justcomment one, the most exciting
one, which is I want to improvemy skills as a scuba diver.
I started this year.
I really like it, but I'm morescared that it's more scary that
(53:02):
enjoying it.
You know I'm not able to enjoyit yet because it's too scary,
but it's, at the same time,amazing and wonderful.
So I really need to, yeah, justdo more immersions and more
activities on this to avoid thefear.
Andrew Keith Walker (53:25):
You should
do something every day that
scares you.
That's what they say.
In my case, it's trying to getmy kids in the car on time for
the bus.
That's always terrifying If youhave teenagers.
You know what I'm talking aboutthere.
How can they floss for so long?
And on that front, another manwho has teenagers in his house
and yet remains incredibly calm.
Nick, what's your goal for NewYear's resolution?
Nick Bruce (53:49):
Yeah, I must admit I
like barbers, by the way.
I think survive is quite aptand I think the main resolution
I've got is always struggle fortime, and this is like
personally.
So my resolution is to actuallystart using my lunch times.
Rather than have a sandwich atmy desk and work through, it's
actually do something.
(54:09):
Take a break, walk away If I'mworking from home, maybe go for
a short run just to do something.
So that's my resolution is uselunch times.
Andrew Keith Walker (54:17):
That's a
great idea.
Time management.
You see, these are allfantastically constructive.
I think we've got a great setof resolutions there.
Well done everybody, and wehope for all of you at home.
You've also had a good break.
Your resolutions are lined upand, you know, once you get over
the obligatory cough and coldthat everyone gets in January,
you're going to have a good yearto a good year with us as we
(54:41):
take you through the challenges,complexities and the run up to
April the 29th and then help youmop up any problems that crop
up after that.
And so, from all of us here atRegistria, we have to draw
things for a close.
But first of all, no show wouldbe complete without a big thank
you to our virtual studio crew,and that is in no particular
(55:02):
order, starting with the nicestand most efficient person in the
organization, barbara RuizAlonso.
Barbara, thank you.
John Kernan (55:09):
Thank you, Andrew,
Thanks everyone.
Have a lovely year and I hopeyou listen to us throughout the
year.
Andrew Keith Walker (55:17):
That's
fantastic and also, to the pride
of Spain, every regulators bestfriend, it is, of course, lara
Rodriguez.
Lara, thank you very much.
Our head of institutionalrelations.
Barbara Ruiz Alonso (55:29):
Thank you
very much, Andrew.
A lot of energy for everybodyfor, yeah, COVID, this year that
we have ahead.
Andrew Keith Walker (55:37):
It's going
to be a good one, and a huge
thank you to the man who wasoriginally putting a canary in
the wharf.
Then he was never square.
Now he's looking after StMary's axe and he's turning his
health around with healthyhabits of 2024.
It is, of course, ceo Registriaon the UK, mr John Kernan.
Thanks.
Laura Rodriguez (55:53):
Andrew, thanks
listeners and courage.
Andrew Keith Walker (55:58):
That's it.
That's what it's all about.
Talking of courage, the man whois the voice of reason and last
year I'm just going to, I'm not, there's no competition here,
I'm just saying he was my mostregular co-host last year.
So you know all of you need toturn up more regularly.
But the man who is always hereto give you his wisdom on the
podcast is, of course, mrNicholas Bruce.
(56:19):
Nick, happy New Year to you.
Nick Bruce (56:22):
Yeah, thank you,
Andrew.
Happy New Year to everyoneagain.
It's good to know that myclaims of fame is being regular.
I'm wishing everyone a great2024.
Andrew Keith Walker (56:32):
And that's
all from us.
So from everyone here,registria and in the virtual
studio and Liana, our producer,and of course from me, andrew
Keith Walker, we wish you all avery good 2024.
Come back and join us nextmonth when we'll be going
in-depth and under the hood withthe big issues that are facing
market participants as they getready with a mere refit programs
(56:53):
.
And don't forget to join us onour LinkedIn page, that's
linkedincom slash company, slashRegist hyphen tier, where you
can find out all about the show.
You can find links to newresources as we publish them and
our new website and when itcomes on stream, and all the
developments that are takingplace here at Registria.
And in the meantime, from allof us, have a very safe month,
(57:14):
have a good month.
We'll see you in a month.
Bye, bye.