What is the SFTR Delegated Reporting Service from HSBC?
In order to facilitate adherence with trade reporting requirements for in-scope transactions, SFTR permits counterparties to delegate the reporting of their trades to the other counterparty.
To help our clients to meet their reporting obligations HSBC offers a SFTR Delegated Reporting Service. The HSBC SFTR Delegated Reporting Service applies to relevant transactions entered into between your EEA entities and either of our HSBC Bank plc (London) and HSBC France (Paris) entities. The exact terms and operational procedures of service may vary depending on which HSBC site you transact with.
HSBC will provide the Service for its clients where they are trading directly with HSBC. Note that we will not report trades executed through a central counterparty or intercompany trades and we will only report in-scope transactions where specifically agreed between us.
By subscribing to the HSBC SFTR Delegated Reporting Service, you authorise HSBC to report your trade-related data on your behalf. Generally, you only need this service if you are an EEA entity (or EEA-located branch of a third-country entity) subject to SFTR trade reporting requirements.
Reporting your SFTR-eligible trades with HSBC
The below service description is relevant for clients trading with HSBC entities in Europe:
|UK||HSBC Bank plc|
|France||HSBC Continental Europe|
What data is reported?
When subject to SFTR reporting requirements, an EEA counterparty to a trade is required to send data electronically to the Trade Repository of its choice. You will be required to provide HSBC with some of your entity-specific data at onboarding to the Service so that HSBC can populate the reports accurately on your behalf.
HSBC offers a full delegation service
HSBC offers a full delegation model:
- HSBC will produce reporting in line with the SFTR requirements for trades, trade lifecycle and collateral data which mirrors the data submitted by HSBC for its House reporting flows
- HSBC will generate a Unique Trade Identifier (UTI) for each trade
- HSBC will send the data to the Trade Repository (TR) at DTCC
Clients can view the data submitted on their behalf directly at the DTCC using their web tools. HSBC will not provide any additional reporting over and above what can be observed directly at the TR.
Benefits of HSBC Delegated Reporting Service
The Delegated Reporting Service from HSBC will report your in-scope trades with us to a trade repository on your behalf. HSBC currently does not directly charge for the Delegated Reporting Service. However, there are indirect costs, independent of HSBC, to be incurred before you can register for this service (obtaining a Legal Entity Identifier (LEI), for instance).
ESMA expects all entities covered by SFTR to obtain a Legal Entity Identifier (LEI). Several 'Local Operating Units' or 'LOUs' provides global LEIs, which means that they are able to generate LEIs for clients from any country. It is a mandatory requirement for all counterparts to register for an LEI if they wish to use the HSBC Delegated Reporting Service AND to maintain that LEI throughout the life of the reporting service.
Unique Trade Identifier (UTI)
Where you are registered for HSBC SFTR Delegated Reporting Service, you agree that HSBC will generate, supply and report the UTI as part of the trade confirmation, except for trades affirmed/executed through third party platforms. For trades affirmed/executed through third party platforms (Tradeweb or Brokertec for example), the platform will create the UTI and provide it.
How to register for the HSBC EMIR Delegated Reporting Service
You must be a client of HSBC Bank PLC or HSBC France. If you are not a client of HSBC Bank PLC or of HSBC France then the SFTR Delegated Reporting Service is not available to you at this time. Please contact your HSBC Relationship Manager if you would like to discuss the situation further.
It is a mandatory requirement for all counterparts to register for an LEI and to maintain that LEI throughout the life of the reporting service if they wish to use the HSBC Delegated Reporting Service
Please read and retain the appropriate Procedures Manual to fully understand how the HSBC SFTR Delegated Reporting Service operates and how it can support you with your reporting requirements:
- HSBC Bank PLC (PDF, 2.09MB)
- HSBC Continental Europe (French Version) (PDF, 489KB)
- HSBC Continental Europe (English Version) (PDF, 601KB)
To request onboarding documentation or for further information on the Service, email the SFTR Onboarding Team for HSBC Bank plc at email@example.com or contact your usual HSBC representative for HSBC Continental Europe.
You will need to gain access to the DTCC's tools in order to retrieve reporting on the Service's submissions.
SFTR Delegated Reporting Post Brexit
Following the withdrawal of the United Kingdom ("UK") from the European Union, there will be some necessary changes to the Delegated Reporting Service. This is to ensure transactions are reported to the correct TR. At on-boarding to the Service, you will be required to nominate your applicable post transition period regime accordingly.
Last updated: 10 April 2021