CME Global Repository Services Client Q&A


The following information is provided to answer any immediate questions that our clients may have surrounding the wind down of CME European Trade Repository and CME Australian Trade Repository. This list is not exhaustive, and we ask that any additional questions surrounding the wind down are directed to your regular contact(s) or emailed to repositorysupport@cmegroup.com.

General

 

1.     Why is CME shutting down a number of its Trade Repositories?

Following an evaluation of our business portfolio after the acquisition of NEX Group in November 2018, we made the difficult decision to wind down the Abide Financial, NEX Regulatory Reporting businesses and our European and Australian Trade Repositories. This is part of our regular practice of assessing our holdings to align with our businesses and operating strategy.

2.     Are all CME Trade Repositories impacted?

Not all CME Trade Repositories are impacted. CME’s two EU (EMIR) Trade Repositories, CME Trade Repository Limited (trading as CME European Trade Repository (CME ETR)) in the UK and NEX Abide Trade Repository AB (NATR) in Sweden, along with CME’s Australian TR (CME ATR) are being wound down. 

CME’s US Swap Data Repository (SDR) (CFTC) and Canadian Trade Repository (CTR) will remain in full operation with no change in service. 

3.     When is the last date of service by the affected TRs?

We expect that the wind down process will be completed by 30 November 2020.  In setting this timeframe, we have taken into account the needs of our clients to have sufficient time to transition to a new provider.

We recognise that clients will need to transition to new providers as soon as possible to ensure continued compliance with their regulatory requirements and we will work to facilitate and support our clients through this process.

4.     How will CME be helping me through this?

CME will work with our clients throughout the wind-down process to ensure a cessation of operations and to facilitate the transition of our clients to an alternative Trade Repository.  Our relationships with our clients and client service are always our priority at CME Group and that doesn’t change with this announcement.

Data Access

 

5.     Will I be able to continue to access my data after the Trade Repository is wound down? 

Upon completion of CME’s wind down of CME ETR and CME ATR, the data will no longer be accessible through CME.  All applicable data will have been moved to an alternative Trade Repository selected by TR Users (or, in the case of CME ETR, selected by CME if a User has yet to port before the backstop porting initiative).  Users should access data from the relevant recipient TR following the porting of their data. 

6.     Is it possible to obtain a copy of all the data reported by or for me to CME ETR or CME ATR?

Yes, CME will accommodate all such data requests made in writing (to repositorysupport@cmegroup.com) and will be fulfilled within 30 days of request.  Data will be provided in a CME specified data layout in CSV format.  The final date for a request of a copy of data reported for active registered clients is 30 October 2020.  Requests for a copy of data may only be made by active registered TR clients.              

7.     Who can request a copy of the data held at CME ETR or CME ATR?

Any firm registered with the relevant TR that is acting as the reporting entity, reporting party or asset manager may be able to request this information. The request should be provided from the verification officer registered with the relevant TR. 

Data Submission

 

8.     When should I stop reporting to CME ETR and/or CME ATR?

For clients that have chosen an alternative TR to port their data to, reporting to CME ETR and CME ATR must be completed by Friday 23:59:59 UTC before the relevant porting weekend (see Q9 below).

For backstop porting and remaining clients who have not previously directed their porting to an alternative TR, final reporting to CME ETR and CME ATR must cease by 23:59:59 UTC on 13 November 2020.

9.     Why does CME ETR have a backstop porting process and how does it work?

The backstop porting process is designed to facilitate the transfer of CME ETR client data to a relevant alternative EU registered trade repository selected by CME. Under the backstop porting process that selected trade repository will accept the transfer of such data for those CME ETR clients that have not ported their own data to a successor trade repository prior to the final deadline determined by CME.  

CME ETR will transfer the data over one or more phases and will notify the client of the selected trade repository to establish a relationship for retrieving the data and on-going reporting for open trades and positions.

CME ATR does not intend to transfer or port data on behalf of customers to an alternative ASIC trade repository. It is the responsibility of CME ATR customers to ensure their reporting of data for open trades and positions is transferred to an alternative ASIC trade repository prior to the deadline determined by CME (see Q11 below).

10.  How do I ensure that my recent data submissions have been made available to the relevant regulator?

Clients can confirm that submitted data has been sent to the relevant regulator by accessing the CME ETR or CME ATR User portal or viewing reports.  Data that appears in the TR system is all made available to the relevant regulatory authorities.

Data Transfer/Porting

 

11.  How do I transfer my data to my selected new TR?

For EMIR data (CME ETR)

All data transfers will be performed by CME ETR to the relevant recipient TR following ESMA mandated portability guidelines on withdrawal porting.  This process begins by contacting CME at repositorysupport@cmegroup.com and discussing preferences on TR and timing.

For ASIC data (CME ATR)

Open trades /positions held in CME ATR should be terminated by the client (CME recommends Fridays) following completion of life cycle reporting for the day and reported to their chosen TR on the next good business day (CME recommends Mondays). This should be done as new records using the same Unique Trade Identifier (UTI) reported to CME ATR.

12.  What data will be transferred to the new TR?

For EMIR data transfers, it will include all historical data (inclusive of lifecycle and rejection reports) and open positions data. 

For ASIC, historical data will not be required to be transferred to a new TR.  Open trades/position must be reported by the client (or its designed reporting service provider) to the new TR.

13.  When can I begin to move my data to a new TR? 

CME recommends that firms initiate their moves as early in the six-month wind-down period as possible to avoid timeline back end congestion and priority with any vendor aiding in the process. Transfers should take place no later than 15 November 2020. 

For CME ETR, any firm who has not initiated and completed their move to a new alternative EMIR Trade Repository by 15 November 2020 will become part of the CME ETR backstop porting phase.

CME ATR does not intend to transfer or port data on behalf of customers to an alternative ASIC trade repository.

14.  Does CME recommend a TR?

CME does not recommend any specific TR. We will work with our clients to help them transition their reporting to their chosen TR, regardless of the destination.

15.  How long does the porting process take?

For EMIR data transfers, a tri-party porting form is involved which can typically take up to two weeks to arrange and complete.  Technical integration to a new TR will depend on the client and new TR.

For ASIC, data is not transferred by CME ATR to the new TR.  See Question 12 for more details.

16.  What happens if I do not transfer my outstanding TR data prior to the end of the wind-down timeline (30 November 2020)?

Any CME ETR client who does not initiate and complete a successful data port to an alternative TR by 15 November 2020 will be processed by CME ETR (as applicable) on their behalf as part of the wind-down backstop porting initiative. The backstop initiative will be executed by CME between 16 November 2020 and 30 November 2020.

Brexit

 

17.  How will Brexit impact the wind-down of CME’s EMIR trade repository (CME ETR)?

The CME ETR trade repository wind-down process will conclude on or before 30 November 2020; prior to the current timetable for the conclusion of the UK transition period (on 31 December 2020).  As such, no specific Brexit arrangements are required for the wind down of CME ETR.  CME ETR clients are advised to review the Brexit plans of their selected alternative EMIR trade repository to determine the impact of the Brexit transition process. 

Billing & Fees

 

18.  How will my annual membership fee (AMF) be handled? 

Clients with an anniversary date between 30 May and 30 Nov 2020 will not be assessed a new annual membership fee but will continue to have full access until their termination effective date.

CME TRs will offer a prorated refund on the AMF for clients with a previous anniversary date occurrence between 01 Dec 2019 and 30 Apr 2020. The prorated amount will be calculated based on the number of whole months (including the anniversary month) between 30 May 2020 and the next anniversary date (month).

19.  How will my submission fees be handled?

Clients will continue to be liable for any new submission fees until they provide the notice referenced above or the TR ceases operations, whichever is the earlier.

20.  Will porting out of CME incur additional fees?

CME Trade Repositories will not charge any port out fees.  Recipient trade repositories may charge fees related to data ported in and should be reviewed in the TR selection process.

Contractual Agreements

 

21.  Do I need to terminate my agreement with CME or will that be done automatically?

CME will confirm the termination date of CME ATR and CME ETR contractual agreements with an Advisory Notice no later than 30 May 2020. No further action is required by TR clients to initiate the process.  The effective date of the termination shall be 30 November 2020.  CME TR clients may request in writing (to repositorysupport@cmegroup.com) an earlier effective date following a successful port to an alternative trade repository. Porting data out will not automatically initiate an earlier termination of a contractual agreement unless explicitly requested by the firm.

22.  Will I continue to have access to the Trade Repository system once my contract is terminated?

Client access to TR systems will be removed upon the contract termination effective date.  Clients must undertake any intended actions (porting and/or data access) prior to the termination date.

Regulatory Engagement

 

23.  Are regulators involved in the wind-down process?

CME has engaged with applicable regulatory authorities in the planning and execution of the wind down process for CME ETR (ESMA) , NATR (ESMA) and CME ATR (ASIC).  CME will remain in ongoing dialogue with these regulatory authorities during the process.

24.  Will my regulator continue to have access to trade repository data at CME following the wind-down completion?

No, following the wind down of trade repository activities and the transfer of repository data, CME will not retain derivative data in an accessible form or otherwise provide access to derivative data to client or regulatory authorities or any other person.

EMIR Reconciliation Process

 

25.  What does the wind-down mean for past data processed by CME ETR into the EMIR inter-TR reconciliation process?

CME is intending to follow the ESMA mandated portability process under the withdrawal scenario when transferring data to the relevant chosen TR(s).  As a result, all previously paired, matched or reconciled open transactions will be unpaired while being transferred to the new TR.  These transactions will subsequently undergo the EMIR inter-TR reconciliation process at the new TR.

Client Support Services

 

26.  Who should I contact for enquiries related to the EMIR or ASIC trade repository wind-down? 

Please contact repositorysupport@cmegroup.com for any initial enquiry.  If you have a regular relationship manager, you may also copy that person in to the email. 

27.  What levels of support can I expect during the wind-down period?

Over the wind down period there will be no changes to hours of support or your email and phone number contacts. CME Group recognizes that an orderly wind down of the businesses is of paramount importance and is committed to support our client fully during the wind down period.