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KEEPING UP WITH EUROPEAN MARKET INFRASTRUCTURE REGULATIONS

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Mastan Momin

By Mastan Momin, Director, Head of Regulatory Transaction Reporting group at SS&C GlobeOp

Mastan Momin

Mastan Momin

The G20 commitments have significantly increased the levels of disclosure, granularity, traceability, and regularity of reporting requirements across the globe. The high standards expected by regulators are a challenge to all market participants. The only thing that is constant with the regulatory requirement is the continual change.Since 2014, the European Market Infrastructure Regulation (EMIR) transaction reporting implementation has been wrought with challenges. While the industry looks at the current data quality issues, European regulators are requesting more granularity on the transaction reporting.

SS&C has seen several key trends emerge from this evolving regulatory climate.For example, firms are beginning to leverage technology providers to help them comply with regulations, improve data quality, increase transparency and consistency, and reduce systemic risk and compliance costs.

Large banks likely to move away from delegated reporting

Large banks are likely to move away from providing buy-side clients with delegated reporting services for over-the-counter (OTC) derivatives and exchange-traded derivatives (ETDs) as required under EMIR.

Banks could continue to offer the delegated reporting for a short term, as the service is tied to the execution and clearing fees. We are hearing feedback that larger banks are less willing to offer this service, and the implementation of the revised RTS would add another layer of complexity to their delegation model.

Revised EMIR RTS: what is changing?

The European Commission carried out an extensive assessment to ensure that the EU legislation is working effectively and efficiently. As a result, the revised regulatory technical standards (RTS) and implementing technical standards (ITS) on reporting under Article 9 of EMIR were published in the official journal on 21 January 2017. They will become applicable on 1 November 2017. All the reports submitted upon the date of the revised technical standards on reporting under EMIR must be compliant with the new standards.

The European Securities and Markets Authority (ESMA) has clarified the fields and the descriptions in the revised RTS. It added the guidance provided in Q&A to the regulatory text and increased the number of fields from 85 to 129. The new table will have 35 counterparty data and 94 common data to report.

In the revised requirements, sourcing the data and implementing the changes will be very difficult and complex. The changes include:

  • Unique Trade Identifier (UTI): Until global UTI is available, a UTI must be agreed to by both counterparties. ESMA added the hierarchy to the UTI generating party. ESMA stresses the importance of the counterparties agreeing to the report’s contents (including UTI) in a timely manner before submitting it to trade repositories.
  • Product classifiers: The product must be classified with an endorsed Unique Product Identifier (UPI) or a Classification of Financial Instruments (CFI) code. For the products identified through International Securities Identification Number (ISIN) or Alternative Instrument Identifier (AII), a CFI code must be specified. For products for which ISIN or AII are not available, an endorsed UPI must be specified. Until UPI is endorsed, those products will be classified with a CFI code.
  • Product identifiers: The product must be identified through ISIN or AII. AII must be used if a product is traded in a trading venue classified as AII in the register published on the ESMA website. In addition, the Association of National Numbering Agencies (ANNA) will release the Derivatives Service Bureau (DSB) platform for user acceptance testing in late Q1 2017. The DSB will go live in October, 2017 to deliver ISINs for the derivatives market.
  • Identification of index and baskets: The index must be identified using ISIN. In a case of basket, each basket component that’s traded on a trading venue must be identified with an ISIN.
  • Collateral reporting: Segregated information of margin must be reported; initial margin posted, initial margin received, variation margin posted, variation margin received, excess collateral posted, and excess collateral received must be reported daily.
  • Reporting of valuations: For trades centrally cleared, central counterparty’s valuation must be reported. For trades not cleared by a CCP, the methodology defined in the International Financial Reporting Standard 13 “Fair Value Measurement” must be used for reporting the value of the contract daily.

Trade repositories reconciliation information

Pairing and matching are the two reconciliation steps that are performed by the trade repositories to ensure the records submitted by both parties are reconciled efficiently. The first is the pairing process, where the Legal Entity Identifiers (LEIs) and UTIs are matched to pair the two trade submissions. The second is the matching process, where all reported data of a paired submission are compared.

According to DTCC’s GTR service has 26 percent of the market share of all transactions under EMIR; RegisTR has 34 percent, UnaVista 12 percent, CME 17 percent, ICE 10 percent, and KDPW 1 percent. Trade repositories have the responsibility to perform reconciliation internally and with other trade repositories as per the interoperability provision. This is to ensure that the trades reported by both parties are accurate and further avoid duplication of the transactions. The recent number published by DTCCGTR had the Inter-TR reports matching the rate at 0.59 percent (the 99.41 percent of the records submitted by both counterparties to different trade repositories don’t match).

UTIs have continued to be one of the main reasons for higher unpaired transactions at the trade repositories. Each reported derivative contract is required (by Commission Delegated Regulation [EU] No 148/2013) to have a UTI. The regulation requires that the UTI is unique but does not de ne how it should be generated or by whom. European regulators were late to clarify which counterparty to a trade is required to produce the UTI. However, unsurprisingly, there are many cases where both counterparties are independently producing UTIs and not exchanging them. As a result, the pairing rate is low. Still, with DTCC GTR, 28 percent of the records are unpaired. This has slowed down regulators’ ability to monitor the systemic risk.

The regulatory expectation is that all trades must be matched, which is a rather complex and sophisticated request. Deep learning techniques would be needed to analyze and resolve the billions of already-submitted EMIR transaction records. 

Cost-effective solution

Firms value greater oversight and governance when it comes to regulatory compliance. They do not want regulators knocking on their door. Regulations such as EMIR, Markets in Financial Instruments Regulation (MiFIR) and Securities Financing Transactions Regulation (SFTR) coming at different times and the shifting goal post of various laws has not made it easier to prepare. It is becoming increasingly costlier to run the business, execute growth strategy and onboard new regulations.

In principle, the regulation can contribute to an action plan through impact analysis, requiring firms to think through the regulatory non-compliance outcomes, and demanding justification for taking strategic actions. One of the aspects should be measuring and improving the perception of regulatory changes. There
is no magic wand to resolve the regulatory challenges. It is an extensive and tiresome work e ort to make a decision and to implement a solution.

Investment managers must look to automate the production of regulatory reporting so they can achieve regulatory compliance on time and at a reduced cost. Centralizing the data from different sources, leveraging security master, valuation, collateral, counterparties (and more) to create a reporting hub is proving to be beneficial in the long term. A regulatory reporting hub can be built on an end-to-end model, including the technology component, data re-use,
and transformations. Firms must consider regulatory compliance as a key component of their business strategy.

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Time for financial institutions to Take Back Control of market data costs

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Time for financial institutions to Take Back Control of market data costs 1

By Yann Bloch, Vice President of Product Management at NeoXam

Brexit may well be just around the corner, but it is market data spending that financial institutions are more interested in taking back control of right now. In fact, other than regulatory equivalence post the transition period, it is hard to think of a more prominent issue right now than the rising cost of market data. According to analysis at the end of last year by Burton Taylor, global spend on market data topped $30 billion in 2019. With costs showing very little sign in coming down, at least in the short to medium term, now has to be the time for market participants to better grasp of not only what their costs could be at the end of the month, but also the precise areas of business consuming the most data.

The problem has been, and still is, seeking out those month-on-month cost anomalies. For example, why is it that fixed income and FX derivatives costs have all of a sudden doubled compared to the previous month? The trouble is it is nigh on impossible to get accurate answers to questions like this because the vast majority of investment firms have no fullproof way of analysing how spending evolves over time. In certain cases, financial instructions can experience a 10%+ increase on their monthly market data vendor bills.

It is not hard to see why – as every small incremental cost mounts up fast. First there are the direct costs for one or more sets of data – which leads to billing getting far more complex. Sure, a market data vendor may be adding lots of different add-on services to help clients save money, but at the same time, they will also be adding on more costs. If this was not enough, there are also the indirect costs around data governance and regulatory compliance. New rules, such as the Fundamental Review of the Trading Book (FRTB), means that investment banks will have no choice but to consume a lot more data to be able to run models and back testing.

All this begs the question; how exactly can firms gain more control of their market data spending? A good place to start is trying to reduce waste. This involves firms making sure they do not request new sources of data from their vendors that they are not going to use. If data vendors charge for every single piece of data that the client requests, then the client needs to make sure they are going to act on this information. Then there is the recycling of the data. Say an investment fund needed a new piece of data instantly, and also needed that same piece of data at the end of the day. If the fund manager already has the data, they surely, they do not need to request it again? It is all about being smarter about reusing whatever data the fund manager has received previously. After all, different trading desks are all consuming data and requesting information through the data management team, but it is hard for the trader acting on the data to work out how much the data actually costs. This is why being able to allocate these costs to the different trading desks is key.

When all is said and done, the only way financial institutions can harbour any hopes of overcoming this longstanding data cost problem is by deriving more insights to ensure they a squeezing every last drop of value from their market data. Technological advancements mean that firms can now keep right on top of not just their data direct costs, like complex billing, but also the indirect costs around regulation. With so many other cost pressures across the business right now, it is time financial institutions take advantage of new technologies to finally address the issue of rising market data costs that has, frankly, plagued the industry for too long now.

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Cash was our past, contactless is our present, contextual payments are the future

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Cash was our past, contactless is our present, contextual payments are the future 2

By Jason Jeffreys, founder of FETCH

$6tn in the next five years, this is how much the world will spend through contactless payments, according to analyst firm Juniper Research. For many of us who have discovered and since relied heavily on contactless payments since its introduction in 2007, either through card, phone, or watch, or those of us who have taken a stroll down a covid-era high-street to see shop windows adorned with “card payment only” signs, this is hardly a surprise. Even the Church of England in 2018 equipped 16,000 religious sites with terminals to allow for contactless donations. So what is behind this rise? And what is next?

The switch from cash to contactless is a transformation of payments that is driven by four key factors: speed, security, accessibility, and hygiene. While businesses and customers alike have felt the immense benefits of the cash to contactless transition, the next iteration goes further by digitally transforming the entire transaction process. It’s that potential which pushed me to launch FETCH – technology that allows customers to order and pay from their phone, anywhere. By exploring the benefits already felt by our contactless present, I hope to show you why I’m excited to be part of the contextual payments future.

Speed

Aldi is all about low prices and this is achieved with efficiency – that is why their checkout staff are trained to scan as fast as possible, it’s why their barcodes are huge, and it’s why you can’t keep up. It’s all in the name of efficiency and cost saving, and contactless payments make this possible.

While increasing the rate of transactions has a direct impact on money through the till, there is an increase in the perceived speed which does wonders to get customers back through the door. Shoppers may have spent an hour or more in-store but their direct interactions with the shop and staff were quick and timely and that’s the experience they remember and the impression they build of the brand.

Aldi are not alone in realising this and while it is easy to point to the impact that contactless has had on the retail sector, its revolution has slowly crept into hospitality –  an industry notoriously late at adopting new technologies.

High-street coffee shops rely on getting as many people as possible through the doors and back out again. They want as little disruption to your day as possible but more importantly, they want to process as many payments per hour as possible. Cash transactions are slow in comparison to a single tap, so for the coffee shops, this means fewer transactions per hour and money lost. For businesses in this sector who rely on periodic rushes, measuring performance per hour is a necessity and maximising revenue over these short windows is so important.

For reasons obvious to anyone who has been to a crowded hospitality venue, stood at a crowded bar or waited for waiting staff during a busy dinner rush, the businesses in this space already running on contextual ordering systems like FETCH have all reported a vastly improved staff and customer experience in hospitality venues. While it may be difficult to spot how these benefits can be felt in retail, this reality is not bound to fiction or the distant future – it’s being pioneered already in retail by Amazon.

In a well documented glimpse into the future of shopping, Amazon’s latest Seattle store removes the transaction element completely. Instead, you put your items in your trolley as you go round the shop, and the sensors and cameras accurately and automatically recognise the items, keeping a track and total, before taking payment automatically and digitally through your Amazon account once you walk the trolley back out of the store. Can you imagine standing in a supermarket queue to pay once you’ve experienced the ease, simplicity and effortlessness of that?

Accessibility

Smartphones have got smarter and they have revolutionised the way we get through the day. From how we discover, connect, and socialise, to how we organise, learn, navigate and search for answers – rarely an hour goes by where we aren’t using our phones for something.

As time moved on they only grew to become more capable, responsible for managing more aspects of our lives, and it was only a matter of time before they were capable of handling secure contactless payments. The leap for people to trust their smartphones with just one additional task was tiny.

When you couple this with debit and credit cards being enabled with contactless technology by default, the rise of wearables, and e-commerce growing massively, the results are clear – people are more trusting of online payments, are more familiar with buying in this way, and have more ways of making contactless purchases, than ever before.

In fact, a Mastercard survey in 2016 indicated that Brits carry less than £5 in cash on average, with 14% of people surveyed carrying no cash at all, and 1 in 10 replacing wallets and purses altogether, opting for a simple card in the pocket instead. Figures which have no doubt grown even starker since 2016.

When we take this into consideration with 99% of 16-24 year olds, 98% of 25-34 year olds, and 95% of 35-54 year olds all being smartphone owners, we begin to see the inevitability of contextual payments as the next iteration and how the response to contextual payments will be positive and welcome; something FETCH clients and the vast majority of their customers can all attest to.

Security

Cashless payments means no cash in the till or on-site; no chance of mistakenly accepting fraudulent notes or coins; no trips to the bank to deposit or withdraw cash for the till; the end of time spent counting money every day, and the end of discrepancies which occur from this.

It limits the levels of theft, switches businesses over to an accurate, secure and efficient system, and gives business owners their time back. It makes tax returns, financial planning and forecasting and more all possible, easier and quicker and in short, it makes businesses stronger.

Jason Jeffreys

Jason Jeffreys

Contextual payments go further by offering really insightful data of what happens before and after people decide to part with their money; for example, how long they spend browsing before ordering, what they look at, what they’ve missed, when they order next and more. This means you are informed and can redesign and improve the user journey so it works better for you and your customers, all based on accurate, relevant and timely data.

As contactless payments evolve to contextual ordering, it’s important to choose a system that easily integrates with the wider business and your systems so you can continue to access the benefits of contactless. That’s why from day 1 of building FETCH I put so much emphasis on ensuring it integrates with one of the biggest and most popular POS systems in hospitality.

Hygiene

Initial adoption has long been the biggest barrier to widespread, sustained use of new technologies and going cash-free is no exception.

Given that the coronavirus thrives and passes through human contact and shared surfaces, going cash-free and contactless was a small, easy and obvious change to implement for businesses to become covid-secure and safer for customers and staff.

FETCH and other contextual payment systems are being used to go beyond this, to keep staff and visitors safe by limiting human contact beyond just payments. In our case, we have allowed hospitality customers to continue to browse, place their orders and pay, just as before, but without the need for repeated human contact at every single stage.

Given the health imperative and coercion from governments, local authorities and health bodies to switch to contact-free operations, businesses who may have once been years away from this change are laying down the infrastructure today out of necessity and it will be no surprise if contactless becomes a staple long after the coronavirus has left.

Post-coronavirus, contextual ordering offers businesses the chance to let the technology take care of these minor tasks, giving staff the space to instead dedicate their time, talent and energy towards elevating the overall experience. It’s the health imperative that acts as the gateway to this.

What does this transition mean for businesses? With visible consideration and effort put into hygiene, you are making your customers feel safe and cared for; by making transactions quick and painfree, you are giving your customers time to spend on the experience they came out for in the first place. In the process, you have created the ideal conditions for consumers to spend money and given them the confidence to do so.

I’ll end with the picture UK Finance data has painted through multiple annual payments reports: in 2006, 62% of all payments in the UK were made using cash; three years later it dropped to 58%; in 2016 the proportion had fallen to 40%; and just two years after that, cash formed just 28% of all UK payments. With a pre-covid prediction envisaging that by 2028 fewer than 1 in 10 payments will be made by cash, the widespread, covid-induced encouragement, adoption and enforcement of cashless policies in retail and hospitality has surely brought that many years forward.

Contextual ordering is the next inevitable iteration and if you were one of the few who reaped the benefits of going contactless early, you have the chance to be ahead of the curve once more. A welcome future for a multitude of industries is being set around us today.

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The Rise of Contactless Payments

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The Rise of Contactless Payments 3

By Bilal Soylu, CEO of XcooBee

Today, banks involved in the issuances of credit cards, and companies at the nexus of merchant services, are experiencing a rare event in the industry.

For years, digital payment innovators fought a hard battle to adopt contactless systems and create standards. The effort and push came from companies with much of the effort directed at consumers to adopt their methodology. Whether it is Samsung Pay, Google Pay or Apple Pay they all had to overcome similar hurdles – consumers were reluctant to adopt a technology that did not have a sufficient number of merchants; thus, the progress was slow.

The COVID-19 pandemic rewrote the script in a whirlwind. All of a sudden, consumers began to demand contactless payment experiences in every way imaginable. The supply side push has turned into a demand side pull and the adoption rate is spiking.

This left banks, originators and companies involved in the eco-system with an interesting dilemma – fast decisions have to be made as to which digital technology to invest in and do they bind themselves, for multiple years going forward, to a specific infrastructure.

While previously the belief was that this could be explored over a longer period of time, the current reality is that these decisions are forced on institutions “overnight”. In this light, there are many different aspects to contactless payments and originators, and banks need to make smart bets on which type should be supported.

So, let’s look at all the relevant elements of contactless payments to explore a better model for institutional support.

General Drivers of Contactless Acceptance Growths

Safety

Physical safety from virus infection by avoiding touching 3rd party equipment or allowing safe distancing from other people and/or equipment is the main driver today. It has been emphasized by many epidemiologists as a basic requirement for conducting business. Consequently, it will be no surprise that safety is the factor that underlies the rapid adoption of a number of contactless payment technologies by once reluctant consumers.

We expect this to be a primary driver well into 2021. Thus, any technology to be rolled out in the short term should enhance safety in some form or contribute in a way to the improvement of safety.

Security

An early benefit highlighted and emphasized by contactless technology providers was the data-security aspect that surrounds the transaction. Rather than exchanging the actual credit card number, for example, a tokenization is performed to create transaction specific tokens that are then used to complete the transaction. Even when intercepted, these tokens cannot be used outside this transaction and, thus, the approach is considered to be more secure.

Although the data-security value was incessantly marketed to consumers, most had, and still have, a limited understanding of the implementation of the technology. Thus, the appeal to the consumer with this benefit was not successful. However, the increased security elements were a clearer benefit for merchants and issuers. Hence, a steady growth of terminals and accepting merchants was the result.

In general, the tokenization approach to security has been chosen for many types of contactless payment systems, this includes NFC based card chips, digital payments like Apple Pay, Google Pay or Samsung Pay. However, for QR payments the use of tokenization should be verified as there are no current standards that govern its use consistently.

Convenience

Convenience was the aspect of many contactless payments system that appealed the most to consumers prior to Covid-19. The ability to either very quickly conduct a transaction or very flexibly conduct a transaction drove consumer adoption. For example, being able to load many payment methods onto a mobile device that users carry with them anywhere increased the appeal of use to consumers.

Thus, when evaluating a particular contactless payment technology with a longer-term outlook the convenience aspect should be emphasized. Given the historical basis, consumers are very likely to be attracted by this aspect as the main driver of adoption again. A financial institutions’ post-Covid planning and investment models for contactless technology should consider this to be a major aspect.

Contactless Payment Categories

When we speak of contactless payment systems, we normally refer to any payment technology that can trigger a payment transaction in the physical space with direct consumer presence, but without direct contact with merchant equipment. Thus, we would exclude online and ecommerce transactions for this purpose.

We will focus on the two mainstream contactless technologies, NFC and QR payments, and review them here. Other contactless payment technologies exist but have not reached widespread adoption so we will only provide brief overview of those.

NFC Payments

Technology

Near Field Communication (NFC) payments are the earliest form of contactless payments that found acceptance in the markets. Generally, two devices are needed and must be near each other to communicate via radio signals. Both the reader (interrogator) and sender (tag) must be within 4cm (1.5in) for the transaction to be initiated. ExxonMobile’s Speedpass is widely believed to be the first implementation of this touch and go type of pay experience that has come to exemplify NFC based contactless payments.

There are two common sub-categories from that technology today; The single card-based sender (tag) and the mobile-phone-based sender (tag). The mobile phone-based application tends to be more flexible allowing consumers to combine multiple cards into one mobile-wallet that is secured with some form with biometric access.

Market

However, NFC signals are not uniform and different standards are used in the Far East (i.e. Japan) rather than in Europe.

NFC payments found early success in developed western markets where the population already had easy access to banking and bank issued card-based tags. However, in countries where the banking system developed later and card-based payments were not common, NFC payments did not flourish.

Thus, today, the market for NFC is mainly concentrated in Europe, Japan, and US.

Activation

The roll out of NFC requires hardware on the merchant and consumer side. The merchant hardware is normally The Rise of Contactless Payments 4leased, and leasing programs have been steady revenue generators for those companies. Whereas, today, the global contactless Point of Sale (POS) terminals market is poised to grow by $5.54 bn during 2020-2024, progressing at a CAGR of 16% during the forecast period, according to research done by Technavio.

However, with the pandemic, the speed of system activation has been a key criterium for selection of the technology. In this context, delivery of hardware, setting up of POS systems and testing connectivity slows down rollouts and potential revenue.

Similarly, requiring consumers to be equipped with supporting hardware may also introduce a friction element, especially in markets where NFC has gained less momentum.

QR Payments

Technology

QR codes are like 3D barcodes. The user scans the QR code via a smartphone and the smartphone, then interprets the barcode and a related website or application may complete the payment process. Like NFC, this can be done very quickly without any contact between smartphone (reader) and the item or display using the QR code.

Normally, QR codes are immutable, meaning that once generated they do not change. However, there are now dynamic smart QR codes, like the ones Xcoobee offers, that can overcome this limitation.

Market

QR codes found strong distribution in markets where banking reach was limited in some form through government or market forces. The QR payment process, in many markets, also exemplifies a jump to direct digital payment, bypassing much of the banking system for purchase transactions. Especially when QR payment systems are connected to mobile wallets the provider of the wallet handles all transaction steps in-system, reducing friction and creating an ease to use and adoption. They have found popularity mainly in China, where AliPay and WeChat pay are gaining dominant market shares.

However, with the advent of COVID and the speed advantages in implementation and cost, other non-traditional markets such as EU and US are seeing dramatic increases in use of QR payments as well.

Activation

Activation of QR code payments commonly requires merchants to simply print codes, which can be accomplished with less hardware. The integration into bank systems is handled via merchant or bank app and the consumer simply requires a smartphone.

While bank offerings in this segment tend to be limited, given the simplified requirements, QR implementation can be quick for merchants to roll out.

Other Contactless Options

There are other contactless payment technologies that are currently competing for market attention and can be grouped into a biometric group and a technology group. The biometric group includes such options as voice, facial or palm recognition-based payments while the technology group includes options like Bluetooth and Farfield-type technologies.

None of these have gained sufficient market share or have execution or security advantages that would push them ahead without concerted efforts from large market-players. Similarly, there is no consumer advantage that would drive a consumer demand-based distribution for these technologies.

NFC vs QR

Which one should you choose to support? Each one of these contactless payment methodologies has advantages and disadvantages. NFC can be nominally faster to use for consumers and more lucrative for banks, but QR codes currently reach a wider market since more phones can read them than those that can read NFC tags.

Operational simplicity and speed also favor QR code activation, but if there is already and existing NFC infrastructure this may become a secondary consideration.

Simply speaking, we are living through unprecedented times, consumers are demanding contactless payment and creating a demand side wave in exchange for safety. How each institution answers this call best will depend on circumstances and context.

Overall, it may be advisable to hedge bets and support both methodologies and offer services based on both. Evaluate customer input, and then, adopt and activate the best option for your financial institution.

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