Barclays EMIR Client Delegated Reporting

14 June 2024

Barclays’ list of known EMIR Reporting errors (timeliness, completeness and accuracy) that may impact Barclays’ delegated trade reporting service are listed below.

 

Field Name Description
Barclays' Significant Impact as per Article 9 This indicates significant issues which we will notify to Barclays’ NCA via Error and Omissions Process
Reference ID This is an internal Barclays Reference, please quote this if you require any further information on this issue
Status This will identify any new, open or closed issues
Field Impacted field
Summary Description of issue
Regulatory Body Impacted Regulatory Body
Asset Class(es) Asset Classes impacted
Regulatory Risk Estimated % impact on overall trade volume (High >5%, Medium 1-5%, Low <1%)
Reporting Impact Accuracy, Completeness or Timeliness issue
Publication Date Date added to Portal

Internal – Transaction Reporting

Barclays' Significant Impact as per Article 9 Reference ID Status Field Summary Regulatory Body Asset Class(es) Regulatory Risk Reporting Impact Publication Date
No TTRT-45073 New Venue of Execution We are currently under reporting trades in which we are receiving the Venue of Execution as XOFF from upstream. Our logic is failing to retrieve the Product ISIN and therefore we are receiving a DTCC rejection. EU EMIR Cross Assets Low Completeness 14 June 2024

No

TTRT-44889

Open

UTI

We have observed for a population of FX trades where we are receiving conflicting UTIs on the Intraday and Confirmation message which is impacting the EOD messages.

UK EMIR

FX

Low

Completeness

07 June 2024

No

TTRT-44736

Open

UTI

Barclays should be GUTI GP for client trades where we are FC but client is NFC+ or NFC-.

EU EMIR

Equities
FX
Rates

Medium

Completeness

07 June 2024

No

TTRT-44560

Open

Country of Incorporation

Post EMIR Refit we are suppressing delegated trades that are domiciled in the Cayman Islands from reporting to the FCA. This is causing under-reporting for delegated clients Rates trades and funds.

UK EMIR

Rates

Low

Completeness

31 May 2024

No

TTRT-44443

Open

UTI

Barclays should be GUTI GP for trades where we are Clearing broker but because MIC is consumed via our reporting platform, it ignores the Barclays generated GUTI as it expects a venue one, but that is not per the guidelines. This is causing rejections.

EU EMIR

Credit
Rates

Medium

Completeness

24 May 2024

No

TTRT-44341

Open

UTI

For a population of trades which were published as electronic with a venue MIC of a SEF, as per waterfall logic it is expected to report with venue gUTI but our upstream system has generated a Barclays gUTI. As This is a SEF trade we should consume and pass their gUTI (ie LEI and UTI together) and not report as XOFF or XXXX to report our own UTI.

EU EMIR

FX

Low

Completeness

24 May 2024

No

TTRT-44352

Open

Underlying Identification Type

If Asset class is populated with EQUI, Underlying identification type should be populated for Equity Exotics and Equity Swaps.

EU EMIR

Equities

Low

Completeness

24 May 2024

No

TTRT-44312

Open

Identifier of the baskets constituents

Post REFIT Portfolio Swaps are being misreported with a single underlier reported in the "Identifier of the baskets constituents" field.

EU EMIR
 

Equities

Low

Completeness

24 May 2024

No

TTRT-44151

Open

MarkitWire Reporting

For Delegated Reporting clients where Rates bilateral trades are executed on MarkitWire, there is a requirement for MarkitWire to perform the Intraday reporting for the client leg. Thus, the delegated client must have their funds onboarded with MarkitWire.

We intend to remove this suppression for all clients to allow us to report both legs Intra-day.

EU EMIR
UK EMIR

Rates

Low

Completeness

24 May 2024

No

TTRT-44177

Released

Execution Agent

For delegated clients, we are correctly including the Execution Agent in the Isnaphot message in the DTCC wrapper and the value is getting reported. However, we are not including the Execution Agent in the confirmation message that gets reported. Thus, the execution agent field is subsequently getting reported as Blank and preventing clients from later seeing the trades.

EU EMIR

FX

Low

Accuracy

17 May 2024

No

TTRT-44152

Open

UTI

Pre-refit the same UTI was used for different counter-parties – e.g. a client message and again for the inter-company message. However post EMIR Refit, the global UTI must be unique for each submission - even if the counterparty values change. A logic change is required upstream.

EU EMIR

Cross Assets

Medium

Completeness

17 May 2024

No

TTRT-44139

Open

Reporting obligation of the counterparty 2

Misreporting of field "Reporting obligation of the counterparty 2" for ETD EU EMIR (both positions and transactions), resulting in false pairing breaks.

Where counterparty 2 is a non EU party (and hence does not have a reporting obligation for EU EMIR), "Reporting obligation of counterparty 2" should be reported as FALSE, and DTCC will not consider the report for pairing and matching reconciliation.

EU EMIR

Future-ETD

Medium

Accuracy

17 May 2024

 

Disclaimer

Whilst you have appointed Barclays to carry out trade reporting on your behalf, pursuant to the provisions of UK EMIR and/or EU EMIR, you retain responsibility for ensuring that any reports submitted are accurate, and to check them for completeness. Clients with DTCC accounts are able to log on to check their trade reports have been submitted accurately. We encourage you to do this, and to let us know if you believe there are any errors in the reporting of your trades by contacting emirdelegatedreporting@barclays.com. For clients who have not previously opened a DTCC account please contact 'GTR Support' for service information and registration details. Further DTCC information on onboarding options for prospective clients can be found at: www.dtcc.com.

Barclays is unable to provide you with advice and, as a result, you should ascertain, using such advice as you deem necessary, your own regulatory obligations, including whether you should be notifying your local regulator of any errors which may have a material impact on your trade reporting. Whilst Barclays is liaising with its relevant regulatory authorities regarding its own trade reporting obligations, this will not extend to your own trade reporting obligations.

© Barclays Bank PLC 2024.