FAQ

Yes, SIX provides a test environment identical to the production environment. By filling out the official application form for reporting users, you will automatically be set up in the test environment.

All details to the SIX Trade Repository Tariff are officially published on our website here.

Your organization can benefit from a volume discount if all reporting firms belong to the same client group (consolidated entities within a group structure). Each client group will benefit from the same volume rebate as defined in the SIX Trade Repository Price List.

A change of fee structures would impact all clients. New fees would take effect at the beginning of the following month. The yearly agreement of the client is immaterial in this instance.

Yes, every reporting firm is required to have an active LEI to  successfully report transactions to SIX.
Service providers can report with their LEI (during testing).

No, both regulations differentiate between certain types of counterparty classes. Due to the fact that FMIA differentiates between small and large financial counterparties and EMIR does not, all clients are requested to classify themselves under the FMIA classification as FC+, FC- (financial counterparties) NFC+ and NFC- (non-financial counterparties).

If a group’s aggregated average notional amount of open OTC derivative contracts on a 30-working-day rolling position is above CHF 8 billion, it is classified as FC+. Physically settled FX forwards and FX swaps are not taken into the threshold calculation. The threshold determination is independent of the systemic relevance of the banking group.

A company is considered an NFC+ if its aggregated rolling average position over 30 working days (including positions of any other NFCs within its group, but excluding hedging contracts) exceeds the threshold in respect of at least one of the following assset classes:

• Credit derivatives: CHF 1.1bn
• Equity derivatives: CHF 1.1bn
• Interest rate derivatives: CHF 3.3bn
• FX derivatives: CHF 3.3bn
• Commodity and other derivatives: CHF 3.3bn

Physically settled FX forwards and FX swaps are not taken into the threshold calculation. If the threshold is exceeded in at least one of these asset classes, the obligations will apply on all derivatives traded by the company, including those entered into for hedging purposes.

Clients with headquarters outside Switzerland might be subject to additional local derivatives regulations, e.g. clients with a headquarters in the EEA fall within the scope of the EU-Regulations EMIR (European Market Infrastructure Regulation). These Clients need to adhere to both regulations when trading with derivatives (Duties within the scope of FMIA as well as within the scope of their own regulation). 

Yes, EMIR requires dual-sided reporting. Therefore, clients established in the EEA and within the scope of EMIR are required to report their trades to a trade repository.

EEA clients can delegate their reporting obligation to the Bank. In this case, the bank submits the transaction, position, valuation and collateral reports required under EMIR on behalf of the client, but the liability for the correctness of the data remains with the client.

The regulator requires that modifications to trades are reported to the trade repository envisaging a log of events against trades. Detailed advice on what that entails is still awaited.

Swaps consist of an FX spot trade (near leg) and an FX forward trade (far leg). The future trade has to be reported. This depends on what core banking system the client is using. If the back-office-system does not reflect two legs but only the trade as a whole then the trade has to be reported. As far as we know most core banking systems reflect two legs.

Banks will have to check with their clients for consensus. We suggest adopting industry best practice.

No, this is not necessary. The SIX Trade Repository system recognises trades that mature naturally. A cancellation would require the trade to be closed on or before the reported maturity date.

Yes, under FMIA there is a possibility to delegate the reporting obligation (as under EMIR). For example, a client in Switzerland can delegate the reporting obligation to a bank in Switzerland.

In general all OTC trades have to be reported to SIX Trade Repository if they are carried out by organizations which are subject to FMIA. If a Swiss bank trades with a foreign bank on a foreign exchange, then the foreign bank has to report to their home repository. If the foreign bank does not report under Swiss law, then the Swiss bank has to report to SIX Trade Repository. It is important that the organizations communicate to each other which side will report.

Only open transactions and positions (if available) where the Pos Quantity ≠0 and the date is in the future, have to be reported on the start date. There is no additional flag of frontloaded transactions however this will be obvious from the execution timestamp when compared to the reporting timestamp.

The field "Unique Transaction Identifier", this means we count per UTI. If the same UTI is used for both a trade and a position, it will be double counted. Check the Price List for further details

•  Reporting Firm ID
• Unique Identifier
• Level (this is also used as we allow firms to use the same UTI for both a transaction and the resulting position, this is not recommended).

Action Type "E" can be used. If a client wants to re-book he can use action type "N" and a new UTI.

No, it doesn’t need to match because non-V relevant data is ignored (except of course the fields required to identify the trade).