REGIS-TR has re-launched a user acceptance testing (UAT) environment for its UK clients that are due to be migrated to its new London-based entity ahead of the Brexit transition period’s conclusion on 31 December.
The trade repository’s (TR) UK UAT was previously activated in time for the 2019 deadline but had to be adjusted and refined as the post-Brexit regulatory landscape shifted.
REGIS’ UK UAT was re-opened on 16 November and a test-run for data migration is booked in for 10 December, which REGIS says offers it a window to work out any kinks before the data drawbridge is raised.
Testing is essential, explains REGIS-TR’s head of business development Nick Bruce, as data cannot be ported after 31 December.
Moreover, as of 2021, the European Securities and Markets Authority (ESMA) and the UK’s Financial Conduct Authority (FCA) require data related to the other’s universe to be terminated meaning anything not successfully ported will be lost.
TRs operating in both markets are engaging in a form of mitosis meaning the European and UK versions are entirely segregated entities with no access to either other’s data, other than during the data migration process.
“The UK environment is a replica of our tried-and-tested EU one so we are confident the platform works, so the test migration is the next big milestone for us,” Bruce explains. “If that runs smoothly then we know we’ve checked the pipes and the process works.
“The biggest concern is that all the clients are ready and open their accounts in good time. Ultimately, we can’t simply transfer all the UK data we have on our system, we need a client instruction and an open account with the UK TR to send it to.”
A quirk in the calendar means TRs will have a few days to validate their new data silos before trading begins in earnest on 4 January.
From 1 January regulations such as the European Markets Infrastructure Regulation (EMIR) or the Securities Financing Transactions Regulation (SFTR) will also need to be identified as either EU EMIR/SFTR or UK EMIR/SFTR, which are, legally speaking, entirely separate frameworks.
On the surface, these reporting rules are mirror images of either other but distinguishing features are already beginning to emerge, with more separation expected as EMIR Refit continues to be rolled out in the EU. SFTR phase four, which brings non-financial entities into its orbit, will only apply in the EU, for example.
The matter is complicated further by the fact the UK’s exchequer and the European Commission are unlikely to agree to a mutual recognition agreement for SFTR, meaning as of January, neither regulator will have rights to the other’s reported data.
