At the ‘Practical Data Governance – Preparing now for the future‘ event held on 8th June 2016 run jointly by the BCS Data Management Specialist Group and DAMA UK, Ian Chapman presented on ‘MiFID II – Data Governance – closing the chasm’.
2. Ian Chapman
•In IT for 30 years, last 20 exclusively in Data
Management
•Mostly FS experience in Banking and Insurance
•BCS CITP and CITP Assessor
•DAMA CDMP
3. Agenda
•What is MiFID II and why does it matter for data
governance.
•What is the data governance chasm and what is the
approach to closing it.
•Practical steps on the journey to governance with
MiFID II.
4. * http://www.bis.org/publ/bcbs239.pdf
BCBS 239* - Where does this fit in?
The ‘Principles for effective risk data aggregation and risk reporting’, commonly known as
BCBS 239 sets out 14 principles.
These principles formalise for the first time in Regulation a set of core ‘Data Management
Principles’ to be applied.
Principle 1
• Governance – A bank’s risk data aggregation capabilities and risk reporting practices
should be subject to strong governance arrangements consistent with other principles
and guidance established by the Basel Committee.
• A bank’s board and senior management should promote the identification, assessment and
management of data quality risks as part of its overall risk management framework. The
framework should include agreed service level standards for both outsourced and in-house
risk data-related processes, and a firm’s policies on data confidentiality, integrity and
availability, as well as risk management policies.
5. MiFID II – What is it?
The Markets in Financial Instruments Directive (MiFID) is the framework of European
Union (EU) legislation for:
• investment intermediaries that provide services to clients around shares, bonds, units
in collective investment schemes and derivatives (collectively known as ‘financial
instruments’) and
• the organised trading of financial instruments
MiFID was applied in the UK from November 2007, but is now being revised to improve
the functioning of financial markets in light of the financial crisis and to strengthen
investor protection.
The changes are currently set to take effect from 3 January 2017, although discussions
are taking place between the European Commission, European Parliament and the
Council of the European Union about the possibility of implementation being delayed.
The new legislation is known as MiFID II - this includes a revised MiFID and a new
Markets in Financial Instruments Regulation (MiFIR).
6. MiFID II
MiFID II and MiFIR empower European Securities
and Markets Authority (ESMA) to develop
numerous draft Regulatory Technical Standards
(RTS) and draft Implementing Technical Standards
(ITS).
550 pages of specification, covering 27 RTS.
Approximately 600 data elements both explicit and
implicit.
10. Buy-Sell Indicator – MiFID II RTS 6
• RTS 6: Regulation on the regulatory technical standards specifying the
organisational requirements of investment firms engaged in
algorithmic trading, providing direct electronic access and acting as
general clearing members
• Information relating to every initial decision to deal and incoming
orders from clients.
• Name: Buy-Sell Indicator
• Format: ‘BUYI’ – buy ‘SELL’ – sell
What is the description …
11. Buy-Sell Indicator – MiFID II RTS
To show if the order is to buy or sell.
• In case of options and swaptions, the buyer shall be the counterparty that holds the right to exercise the option and the seller shall be the
counterparty that sells the option and receives a premium.
• In case of futures and forwards other than futures and forwards relating to currencies, the buyer shall be the counterparty buying the instrument
and the seller the counterparty selling the instrument.
• In the case of swaps relating to securities, the buyer shall be the counterparty that gets the risk of price movement of the underlying security and
receives the security amount. The seller shall be the counterparty paying the security amount.
• In the case of swaps related to interest rates or inflation indices, the buyer shall be the counterparty paying the fixed rate. The seller shall be the
counterparty receiving the fixed rate. In case of basis swaps (float-to-float interest rate swaps), the buyer shall be the counterparty that pays the
spread and the seller the counterparty that receives the spread.
• In the case of swaps and forwards related to currencies and of cross currency swaps, the buyer shall be the counterparty receiving the currency
which is first when sorted alphabetically by ISO 4217 standard and the seller shall be the counterparty delivering this currency.
• In the case of swap related to dividends, the buyer shall be the counterparty receiving the equivalent actual dividend payments. The seller is the
counterparty paying the dividend and receiving the fixed rate.
• In the case of derivative instruments for the transfer of credit risk except options and swaptions, the buyer shall be the counterparty buying the
protection. The seller is the counterparty selling the protection.
• In case of derivative contracts related to commodities, the buyer shall be the counterparty that receives the commodity specified in the report
and the seller the counterparty delivering this commodity.
• In case of forward rate agreements, the buyer shall be the counterparty paying the fixed rate and the seller the counterparty receiving the fixed
rate
• For an increase in notional the buyer shall be the same as the acquirer of the financial instrument in the original transaction and the seller shall be
the same as the disposer of the financial instrument in the original transaction.
• For a decrease in notional the buyer shall be the same as the disposer of the financial instrument in the original transaction and the seller shall be
the same as the acquirer of the financial instrument in the original transaction.
12. Buy-Sell Indicator – MiFID II RTS 6
In the case of swaps and forwards related to
currencies and of cross currency swaps, the buyer
shall be the counterparty receiving the currency
which is first when sorted alphabetically by ISO
4217 standard and the seller shall be the
counterparty delivering this currency.
13. DMBOK – The 10 Data Management Functions
0
1
2
3
4
5
6
7
8
9
10
1
2
3
4
56
7
8
9Degree of Impact
14. What is the Data Governance Chasm?
• Data in many systems
across different LOBs
• Data defined using
external taxonomy by
ESMA
• Changing data
requirements
• Lack of clarity on
reference data for
Instrument (ISIN for OTC
instruments)
• Absences of data from
external source – Market
Volumes etc.
Alignment to existing
Enterprise Data
Management Policies &
Standards:
• Data Stewards governing
data which is new to the
organisation
• Metadata collection for
all new data elements
• DQ Processes covering
the whole supply change
• Accountability identified
for DG Processes
• Data Sharing agreements
in place
16. Agenda Recap
•What is MiFID II and why does it matter for data
governance.
•What is the data governance chasm and what is the
approach to closing it.
•Practical steps on the journey to governance with
MiFID II.