Barclays SFTR Client Delegated Reporting
July 2023
Barclays list of known material errors in the delegated trade reporting service potentially impacting the completeness and accuracy of reporting is listed below.
Internal – Transaction Reporting
| Status | Key | Summary | Asset Class(es) | Category | Publication Date | Business Impact |
|---|---|---|---|---|---|---|
| Open | TTRT-37804 | Mandatory field "Entity Responsible for Reporting" needs to be consumed/captured from internal static data in case of delegated clients where underlying UCITS funds are managed by "Management Company." Where ERFR field needs to be populated by Management company LEI. | Fixed Income Finance, Securities Lending | Internal | June 2023 | Misreporting |
| Open | TTRT-37412 | Suppression of EOD submissions with invalid LEI for Repo/Sec Lending. As an Workaround for this issue, TTRO is advised to rename the LEIOfIssuer instead of deleting them. | Fixed Income Finance, Securities Lending | Internal | June 2023 | Under Reporting |
| Open | TTRT-36811 | When allocation for Collateral & Valuation coming from MarkitPirum failed to locate their Shell trades then OneReg move them to the internal error queue with above exception message. | Fixed Income Finance, Securities Lending | Internal | June 2023 | Under Reporting |
| Open | TTRT-36178 | Misreporting of "market value" field. Requirements for reporting “market value” field: Market value should be reported on a T+1 basis, and calculated as market value = quantity * market price of security as of COB the prior day. | Securities Lending | Internal | March 2023 | Misreporting |
| Open | TTRT-36107 | Over reporting of matured SLEB trades due to residual cash remaining when stock is returned, hence trade remains open in Upstream System. | Securities Lending | Internal | March 2023 | Over Reporting |
| Open | TTRT-35827 | Over reporting of terminated and cancelled inter-entity and delegated client trades, due to Internal suppression rule applied to one side of the trade. | Fixed Income Finance, Securities Lending | Internal | February 2023 | Over Reporting |
| Open | TTRT-35728 | Segway and iRepo are sending an FULLRETURN (ETRM) then a CANCELRETURN (MODI) after a few hours on the very same day which is leading to rejections, as DTCC rejects submission post ETRM as an ETRM can’t be overturned once reported. | Fixed Income Finance, Securities Lending | Internal | February 2023 | Under Reporting |
| Open | TTRT-35727 | For SLEB trades, we expect to report “market value” for SFTR regulatory reporting on a daily basis, based on value fetched from the daily margin render file. We are seeing issues for a population of SLEB trades booked in iRepo, for which no valuation report is generated. This looks to be due to logic implemented in iRepo to exclude certain books from generating an EOD snapshot message. |
Securities Lending | Internal | February 2023 | Misreporting |
| Open | TTRT-35168 | We are under reporting trades for delegated clients (both “optional” and mandatory delegated clients) where execution timestamp of the trade is prior to the date which the delegated reporting setup was completed. For reporting of delegated client trades, currently our Reporting Platform will generate a client report only if execution timestamp of the trade is after the date that delegated reporting setup was completed. This results in under reporting of delegated client trades, and pairing and matching breaks. |
Fixed Income Finance, Margin Lending, Securities Lending | Internal | January 2023 | Under Reporting |
| Open | TTRT-35107 | We expected to remediate below two rejections as in most of the cases one trade (allocation) is being rejected by DTCC with both the messages. 1. The Event date must be less than or equal to Maturity date (End date). 2. The Maturity date (End date) must be greater than or equal to Value date (Start date). |
Fixed Income Finance, Securities Lending | Internal | January 2023 | Under Reporting |
| Open | TTRT-34825 | ICMA recommendations state that "where a standard version of the master agreement being reported has a publication year, this should be reported in field 2.13 Master Agreement Version." ICMA have also provided a list of standard publication dates for various Master Agreements types. “Master agreement version” field for SFTR reporting is currently populated based on the “Agreement Type Version” in our internal system. |
Fixed Income Finance, Securities Lending | Internal | January 2023 | Misreporting |
| Open | TTRT-34149 | The field Method used to provide collateral is currently reported for REPO, SL and ML. For REPO and SL, this field is reported based on Master Agreement Type obtained from internal feed. There is a mapping table in place for different Master Agreement from intenal feed to report Method used to provide collateral. Currently there is no mapping for Master Agreement Type *"BIAG".* The requirement is to include the master agreement type BIAG in the mapping table so that the field is reported accurately. |
Fixed Income Finance, Securities Lending | Internal | January 2023 | Misreporting |
| Open | TTRT-34760 | Misreporting of field “Collateral Market Value”, ICMA SFTR recommendations state that “In reports of new transactions, modifications and corrections, the direction of the collateral transfer should be reported. DTCC reconcile based on parties reporting the same value, but opposite polarities. As we are not considering if we are giving or taking collateral to determine if “Collateral Market Value” is reported as + or – value, matching breaks are generated where we have reported the same value as the counterparty, however we have reported the same polarity. | SFT | Internal | December 2022 | Misreporting |
| Open | TTRT-34027 | We are reporting incorrect maturity dates for agent lending allocation trades, which is causing rejections at DTCC. | Fixed Income, Securities Lending | Internal | November 2022 | Under Reporting |
| Open | TTRT-33599 | Some of the instruments in ESM are carrying MifidCFICode as 'DXXXXX' which is an invalid CFI code from regulatory perspective. As per the regulatory requirement atleast first two letter should be available for a CFI code however here 'DXXXXX' only first letter is present. |
Fixed Income, Securities Lending, SFT | Internal | November 2022 | Misreporting |
| Open | TTRT-33599 | Rejections seen from DTCC on back of invalid CFI – DXXXXX. Correct and complete CFI code to be reported in order for successful submissions. | Fixed Income, Securities Lending | Internal | October 2022 | Misreporting |
| Open | TTRT-33467 | “Currency Of Nominal Amount” is not being reported to DTCC as security is incorrectly identified as “Equity” Internal mapping needs to be corrected to prevent these Misreporting. | Fixed Income, Securities Lending | Internal | September 2022 | Misreporting |
| Open | TTRT-33276 | Trades are being rejected by DTCC (TR) as incorrect “Action Type” is populated on previously successfully submitted trades. | Fixed Income, Securities Lending | Internal | September 2022 | Under reporting |
| Open | TTRT-33281 | Barclays is populating “Maturity of Security” field incorrectly for “Perpetual Bonds”. For perpetual bonds, we should be reporting the default date of “9999-12-31” to indicate that the security does not have a maturity date. | Fixed Income, Securities Lending | Internal | September 2022 | Misreporting |
| Open | TTRT-33313 | Barclays is Misreporting LEI of one delegated reporting client with their parent LEI instead of branch LEI which is not in scope for SFTR. | Margin Lending | Internal | September 2022 | Misreporting |
| Open | TTRT-33518 | For small subset of Repo trades, it is observed that Barclays are incorrectly reporting “Trading Venue” as “XXXX” for all the trades agreed via “Equilend” due to internal system limitation. | Fixed Income | Internal | September 2022 | Misreporting |
| Open | TTRT-33527 | Issue seen specifically for agent lending repo trades with action type MODI, where Barclays is not populating the “Agent Lender” LEI within the report submitted to DTCC (where this field is applicable and should be populated). | Fixed Income | Internal | September 2022 | Misreporting |
| Open | TTRT-32831 | Barclays to include additional floating rate reference rates as per Open ICMA recommendations. JIRA is to enhance static as well as include Open recommended codes. | Margin Lending, Securities Lending | Internal | August 2022 | Misreporting |
| Open | TTRT-32879 | Barclays to extend implementation as per latest ICMA rules on populating manually created CFI’s for 4th & 5th character. | Margin Lending, Securities Lending | Internal | August 2022 | Misreporting |
| Open | TTRT-32999 | Barclays to enhance “Principal Amount at Value Date” field for Tri-party Repo’s in line with latest ICMA recommendations where this field needs to be reported to nearest whole number. Currently Barclays is populating this field as received from “Upstream systems”. | Fixed Income, Securities Lending | Internal | August 2022 | Misreporting |
| Open | TTRT-33036 | As per latest ICMA guidelines, Barclays to update –“Floating Rate Reference period , “Floating rate payment frequency” , Floating rate reset frequency” to weeks rather than days, months rather than weeks or days, and years rather than months, weeks or days. | Fixed Income, Margin Lending | Internal | August 2022 | Misreporting |
| Open | TTRT-32802 | Barclays to include additional floating rebate rate reference as per Open ICMA recommendations. JIRA is to enhance static as well as include Open recommended codes. | Securities Lending | Internal | July 2022 | Misreporting |
| Open | TTRT-32806 | On small subset of trades, it is observed that Barclays is reporting trading venue of SI MIC. As per latest guidelines SI MIC should never be reported and instead “XXXX” should be populated. | Fixed Income, Securities Lending | Internal | July 2022 | Misreporting |
| Open | TTRT-32240 | It is observed that, “Central Securities Depository” participant field is not populated in all lifecycle events. This field needs to be populated with CSD participant & reported ahead if available on all events. | Fixed Income, Securities Lending | Internal | June 2022 | Misreporting |
| Open | TTRT-32334 | As per latest ICMA guidance, Barclays to implement change for Master Agreement to have “Standard Publication” date instead of current “agreement signed date”. | Fixed Income, Securities Lending | Internal | June 2022 | Misreporting |
| Open | TTRT-32670 | As per Open ICMA recommendation, “Collateral quantity / Nominal amount” needs to be populated with negative signage for collateral “Giver” party. Currently being populated as received from upstream without any change in signage. | Fixed Income, Securities Lending | Internal | June 2022 | Misreporting |
| Open | TTRT-32672 | It is seen that Barclays submission with respect to “Other Master Agreement Type” is not in line with latest ICMA recommendations with respect to CCP specific rule book. | Fixed Income, Securities Lending | Internal | June 2022 | Misreporting |
| Open | TTRT-32686/ 32684 | Barclays need to review the logic implemented for “Security & Collateral Quality. Currently small subset of population not being reported correctly. | Securities Lending | Internal | June 2022 | Misreporting |
| Open | TTRT-32687 | For all Tri-party Repo trades, managed by other than JP Morgan need to be populated as “FALSE” as per Open ICMA recommendation. Currently being populated by Barclays as “TRUE”. | Fixed Income | Internal | June 2022 | Misreporting |
| Open | TTRT-32193 | It is seen that Barclays is reporting “Loan Value” field post currency exchange; As per ICMA guidelines currency exchange should not be considered for this field. | Fixed Income, Securities Lending, Margin Lending | Internal | May 2022 | Misreporting |
| Open | TTRT-32199 | It is seen that for COLU submissions, Barclays is reporting “Collateral Market Value” in USD only instead of issue currency. | Fixed Income, Securities Lending | Internal | May 2022 | Misreporting |
| Open | TTRT-32232 | Barclays has identified that, Cash Collateral amount should be reported as “Negative” for the party who is “Collateral Giver”. Currently, Barclays using value as received from upstream without identifying “Giver” & “Taker” | Fixed Income, Securities Lending | Internal | May 2022 | Misreporting |
| Open | TTRT-32259 | It is seen that, “Issuer Country Incorporation” field is not being reported as expected and is not consistent with GLEIF data. | Fixed Income, Securities Lending, | Internal | May 2022 | Misreporting |
| Open | TTRT-31620 | Barclays has identified that small subset across asset class is not being reported out or stuck in internal queue due to incorrect instrument static data. | Fixed Income, Securities Lending, Margin Lending | Internal | April 2022 | Under reporting |
| Open | TTRT-31619 | Barclays has identified that small subset across asset class is not being reported out or stuck in internal queue due to incorrect client static data. | Fixed Income, Securities Lending, Margin Lending | Internal | April 2022 | Under reporting |
| Open | TTRT-30569 | Barclays is sending out EOD feeds for CDR clients where Intraday feed is missing and hence getting TR rejections. | Fixed Income, Securities Lending | Internal | March 2022 | Over reporting |
| Open | TTRT-30684 | It is observed that on small population of Margin Lending trade Barclays need to submit event as “Early Termination” where internal static is deleted or no longer valid. | Margin Lending | Internal | March 2022 | Over reporting |
| Open | TTRT-30310 | Rejections seen in “EOD” submissions across asset class from trade repository as “Intraday” leg is not reported successfully and position is not created in Trade Repository. | Fixed Income Finance, Securities Lending, Margin Lending | Internal | March 2022 | Under reporting |
| Open | TTRT-30667 | For some Fixed Income & securities Lending Exit submissions, Barclays has identified rejections received from DTCC whereby matured/stale trades are still present in the GTR. | Fixed Income Finance, Securities Lending | Internal | November 2020 | Over reporting |
Fixed – Pending Resubmission
| Status | Key | Summary | Asset Class(es) | Category | Publication Date | Business Impact |
|---|---|---|---|---|---|---|
| Fixed – Pending Resubmission | TTRT-32195 | Barclays has identified that for equity securities “Security Type” & “Collateral type” is incorrectly reported as “OTHR” instead of field – OEQU. | Fixed Income, Securities Lending, Margin Lending | Internal | May 2022 | Misreporting |
| Fixed – Pending Resubmission | TTRT-33832 | It is observed that “Fixed Rate” field is misreported for Termination” event where we have “Rerate” event earlier in lifecycle. This field is currently reported with old rate details instead of newly agreed rates. | Fixed Income | Internal | October 2022 | Misreporting |
| Fixed – Pending Resubmission | TTRT-32835 | It is observed that “Haircut or “Margin” field is currently rounded off to nearest whole number. As per ICMA recommendations, this field should be reported with up to 10 decimals. Barclays to implement ICMA recommendations. | Fixed Income, Securities Lending | Internal | August 2022 | Misreporting |
| Fixed – Pending Resubmission | TTRT-30346 | Rejections seen on small subset of Securities Lending trades on back of Open validation put in place by DTCC since June'21. Trades getting rejected as Barclays populating "FALSE" indicator for field "Quantity /Nominal amount" on loan leg. | Securities Lending | Internal | September 2021 | Under reporting |
| Fixed – Pending Resubmission | TTRT-30411 | Following conformance testing Barclays are to enrich their reporting flow of the ‘Earliest call-back date’ field where the values are incorrectly populated for a small population of Securities Lending trades. | Securities Lending | Internal | January 2021 | Misreporting |
Closed
| Status | Key | Summary | Asset Class(es) | Category | Publication Date | Business Impact |
|---|---|---|---|---|---|---|
| Closed | TTRT-35739 | For Client Delegated Reporting, reporting of field "Additional Sector Classification" is mandatory if the counterparty is either NFC- (SME NFC) or if primary corporate sector of counterparty is either Financial & Insurance Activities or Real Estate Activities. If this field is not populated for SME NFC & counterparty having above CSC then DTCC would reject submissions for client leg. |
Fixed Income Finance, Securities Lending | Internal | February 2023 | Under Reporting |
| Closed | TTRT-35646 | Currently we update “Security or commodity price” and "Loan Value" fields in line with daily pricing updates. However “Security or commodity price” and "Loan Value" fields should align with the price agreed at trade execution (and should not be updated to accommodate daily pricing changes). The "market value" field should be updated to reflect pricing updates only. |
Securities Lending | Internal | February 2023 | Misreporting |
Impact Category: Impact Definition
Late Reporting: Trades are not reported within the required timeframe, as set out by the relevant regulator.
Under Reporting: Reports not being sent to/being rejected from the Trade Repository.
Over Reporting: Non reportable reports being sent to the Trade Repository.
Misreporting – Economic Data: Accepted by the DTCC but may not be 100% correct as far as the SFTR Tech Standards are concerned or Accepted by DTCC and meets SFTR tech standards but not strictly correct representation of the trade.
Misreporting – Data: Accepted by the DTCC but may not be 100% correct as far as the SFTR Tech Standards are concerned or Accepted by DTCC and meets SFTR tech standards but not strictly correct representation of the trade.
Misreporting – Events: Accepted by the DTCC but may not be 100% correct as far as the SFTR Tech Standards are concerned or Accepted by DTCC and meets SFTR tech standards but not strictly correct representation of the trade.
Industry: Originating from Third Parties (e.g. DTCC, MarketWire, TradeWeb) or gaps in Industry standards.
Internal: Originating from Barclays systems or processes.
Disclaimer
Whilst you have appointed Barclays to carry out trade reporting on your behalf, pursuant to the provisions of EU SFTR and/or UK SFTR, 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 sftrdelegatedreporting@barclayscorp.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 an 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.
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