AutoPilot for Dodd-Frank Compliance

Monitoring Title VII Trade Reporting Compliance

Provides banks with real-time visibility into the lifecycle of trade events and the ability to monitor regulatory responsibilities for trade reporting

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Requirements AutoPilot Features
Transaction Stitching: The best way to monitor compliance to the regulatory reporting requirements is to provide a graphical tool that alert a user to a potential or actual breach in responsibilities in real-time. Automated stitching across the entire lifecycle of a reportable trade event, represented graphically as a series of milestones.  The user can see in real-time the progress it is making until completion.
Execution Time Tracking: Defined as when the primary economic terms are exchanged by both counterparties. In order to monitor compliance to trade reporting SLA's, it is necessary to inspect the contents of the trade message rather than just the time stamp when it was generated. Retrieves message content and extracts the actual Execution Time as the trigger for the SLA timer. This information is used in conjunction with milestone events gathered as the trade moves through the enterprise.
NACK Management: All trade lifecycle events must be reported to the GTR and positively acknowledged. Any parsing or validation errors associated with the transaction will be reported back to the SD as a NACK message. Monitoring systems must be able to manage the workflow associated with the NACK messages and ensure that reason codes are reported back to trade support for resolution. It is also important that Compliance can easily identify trade reports that did not conclude with a valid ACK message. Automatically detects all trades that do not contain a valid ACK milestone event.
Part 43 Real-time Reporting: states specific requirements for the management of timestamps by swap dealers and major swap participants. These include recording the time to the nearest second when data is transmitted to a registered swap data repository for public dissemination. Native support for Middleware, such as MQ,TIBCO, Java and more seamlessly integrates into the trade flow and contributes timestamps to the transaction stitching process.
Monitor Mandatory Data: Even when a third party entity is used to report a transaction, the swap dealer remains fully responsible for adhering to the regulation and it is therefore vital that Compliance departments can view and monitor transactions and validate key elements such as reporting party determination/override or presence of key fields such as Unique Swap Identifier (USI). The user can view the transaction at any point in the flow and define conditional rules to check against the data in real-time for immediate notification.
Reporting Window: CFTC has defined number of specific “Reporting Windows” for counterparties to adhere to, depending on the swap characteristics and type of trade report. These windows are also scheduled to change one year after compliance. An advanced SLA capability that can track each reportable event against the appropriate time-based (30 minutes after execution) or event-based (by 04:00 T+1 after confirmation date) window. The SLA also incorporates holiday calendars and UTC timestamps.
Reconciliation: It is essential that any compliance department can reconcile their reporting activities at the end of the day against the daily reports generated by the GTR. Reporting capability that enable DTCC submissions and position reports to be automatically reconciled against the application monitoring data that has been gathered at the end of the business day. Reconciliation reports can identify discrepancies between what the firm has reported and what information has been received by the GTR.

 

The requirements for Dodd-Frank compliance can be very challenging for some banks.

AutoPilot can help, by providing:

Feature Benefit
Simple Proactive Analytics – real-time analytics that can keep up with the largest volume of trades and reports that provides proactive notification for pending infrastructure issues. This capability enables users to instantly see transactions of concern such as those with NACKs from DTCC, Euroclear or Clearstream in order to rapidly correct and resubmit them
Correlation – the ability to automatically stitch together all transactions and messages in real-time This enables the user to view complete end-to-end transactions providing business context to IT activities even when these activities span from the distributed to the middleware to the mainframe infrastructure tiers. Generating this automatically and performing it in real-time allows this important activity to keep up with the volume of trades and fluctuations in the market
Visibility – provide a view into compliance that is usable by Compliance Officers as well as one for IT. The dashboard visualizes both transaction data and business milestones and shows the Execution Time, Source System, USI, Asset Class and Trade ID along with other relevant fields The views for IT and Compliance Officers help these two groups work together effectively by providing instant insight into the status of compliance with actionable data appropriate to each group.
Charting – user defined charts that show, for example:
  • All transactions from a designated source such as Calypso, Summit or Murex
  • All transactions that received a NACK milestone, but have not received an ACK
Charting provides effective on-the-fly visualization of current and historical trades specific to the user's query. Being able to chart by business details such as source or NACKs, provides Compliance Officers with meaningful status,
SLA reporting – the ability to support both time-based as well as deadline-based SLAs with rollover on holidays. This feature provides the flexibility necessary to configure and determine SLA compliance based on business requirements.
Calendaring - provides support for business days with the exclusion of weekends and holidays per time zone.
  • AutoPilot also enables the import of custom calendars that can be used with site-specific rules or policies
Automatic accommodation of holidays helps keep system maintenance low.This lets analysis adjust to local policies an important capability in a function that is distributed globally.
History - a searchable, historical repository that enables search
  • By USI, message contents, transaction ID or any combination of fields
  • By transaction status and/or SLA status or transactions that took more than 15 minutes to complete
  • For transactions that took more than 10 minutes to reach a specific milestones
Historical record of Dodd-Frank compliance is required. Providing a searchable capability by business fields makes looking backward an easy task.
Auditing
  • All actions carried out by policies such as shutdowns or restarts are logged
  • Every action is associated to a user
This capability ensures accountability.
Reporting
  • End of day reports
  • Policy statistics
Overall program evaluation and status are enabled via reporting and statistics.