This article describes the factors that are considered to determine whether a submission is considered to be on time per Canadian regulations.
What do the timeliness indicators mean?
- an accepted message that was reported on time
- any message where there is more than 1 hour left to report
- any message with less than 1 hour left to report
means the submission is late
means calculating timeliness does not apply for the message
means missing and/or invalid values were submitted for the fields needed to calculate timeliness
How is timeliness calculated?
KOR TRs
When a message is submitted to the repository, KOR calculates the time it was required to be submitted based on information provided on the message and the applicable regulations.
A message needs to be accepted AND validated to be on time. Submitting a message with rejections before the required submission timestamp does not count - the clean resubmission of that message will be considered on time only if it passes all validations before the required submission timestamp.
KOR RS
When KOR Reporting Services (KOR RS) submits a message to a Trade Repository (TR), timeliness is determined based on the output submitted timestamp recorded when the message is sent to the TR. This timestamp validates that the message was submitted within the required reporting timeframe. The TR acceptance timestamp is not used for timeliness calculations, as processing times at the TR can vary and may take several minutes or longer. This ensures accurate measurement of compliance with reporting deadlines, independent of TR processing delays. The TR must ack the message for KOR to calculate an on time report.
What is a Business Day under Canada Reporting Rules?
A business day is any day other than a Saturday, Sunday or statutory holiday (per CP1's provincial regulator).
Midnight is per the timezone of CP1's provincial regulator.
Where the report is applicable to multiple local counterparty provinces, the nearest timeline shall apply.
How KOR calculates the Required Submission Timestamp
Though KOR's calculations below are according to the latest allowable submission time per the regs, we strongly recommend that your set internal SLA's according to the rule which is the following:
Creation Data: ASATP (practicable being determined based on comparable counterparties located in Canada and in foreign jurisdictions)
Lifecycle Events: End of the business day on which the life-cycle event occurs
KOR determines timeliness based on the ExecutionTimestamp, ValuationTimestamp or the EventTimestamp combined with the Qualified Reporting Counterparty Indicator.
Qualified Reporting Counterparty Indicator: Means a reporting counterparty that is any of the following:
(a) a derivatives dealer;
(b) a recognized or exempt clearing agency;
(c) an affiliated entity of a person or company referred to in paragraph (a) or (b).
CA Creation Data Timeliness
This logic applies to messages where:
- MessageType = Transaction
- Action type = NEWT
- Event type ≠ PTNG
Rule |
Qualified Reporting Counterparty Indicator |
Required submission timestamp |
True |
A qualified reporting counterparty in respect of a derivative must report creation data in real time. If it is not technologically practicable to report creation data in real time, a qualified reporting counterparty must report creation data as soon as technologically practicable and in no event later than the end of the business day following the day on which the data would otherwise be required to be reported. EOD of next business day from the date portion of executionTimestamp |
|
91-507 CP 31(5) |
False |
A reporting counterparty that is not a qualified reporting counterparty in respect of a derivative must report creation data no later than the end of the second business day following the execution date of the transaction. EOD of second business day from the date portion of executionTimestamp |
CA Continuation Data Timeliness
This logic applies to messages where:
- Message type = Transaction
- Action type ≠ NEWT
- Event type ≠ CORR
Rule |
Qualified Reporting Counterparty Indicator |
Required submission timestamp |
91-507 CP 32(1) & (2) |
True |
For a derivative that is required to be reported under this Rule, a qualified reporting counterparty must report all lifecycle event data to a designated trade repository by the end of the business day on which the lifecycle event occurs. If it is not technologically practicable to report lifecycle event data by the end of the business day on which the lifecycle event occurs, a qualified reporting counterparty must report all lifecycle event data to a designated trade repository no later than the end of the business day following the day on which the lifecycle event occurs. EOD of next business day from the date portion of eventTimestamp |
91-507 CP 32(3) |
False |
A reporting counterparty that is not a qualified reporting counterparty in respect of a derivative must report all lifecycle event data to a designed trade repository no later than the end of the second business day following the day on which the lifecycle event occurs. EOD of second business day from the date portion of eventTimestamp |
CA Cleared Termination Timeliness
This logic applies to messages where:
- Message type = Transaction
- Action type = TERM
- Event type = CLRG
Rule |
Counterparty 1 designation |
Required submission timestamp |
91-507 CP 32(4) |
CA |
the recognized or exempt clearing agency through which a derivative is cleared must report the termination of the original derivative to the designated trade repository to which the derivatives data in respect of that original derivative was reported by the end of the business day following the day on which the original derivative is terminated.. EOD of next business day from the date portion of eventTimestamp |
CA Valuation Message Timeliness
This logic applies to messages where:
- Message type = Valuation
Rule |
Counterparty 1 designation |
Required submission timestamp |
"CA" or "DD" |
Reporting counterparty that is a derivatives dealer or a recognized or exempt clearing agency must report to a designated trade repository each business day end of the next business day following the valuation date (date portion of valuation timestamp) |
|
|
NON-DD/CA |
No requirement to report |
CA Collateral Message Timeliness
- Message type = Collateral
Rule |
Counterparty 1 designation |
Required submission timestamp |
"CA" or "DD" |
Reporting counterparty that is a derivatives dealer or a recognized or exempt clearing agency must report to a designated trade repository each business day end of the next business day following the valuation date (date portion of collateral date) |
|
|
NON-DD/CA |
N/A |
Public Dissemination Timeliness
Per OSC Rule 91-507 Appendix C, KOR publicly disseminates messages 48 hours after the execution timestamp for NEWTs, or event timestamp .
A Public message is considered 'On Time' as long as it is received by KOR within 48 hours of this execution timestamp.
Business day calculations are not taken into consideration here - KOR will publicly disseminate the trade exactly 48 hours after the execution timestamp.
Message Type | OSC Regulation | Required Submission Timestamp |
Creation
|
91-507 CP 31 |
For all Counterparty1Designator values 48 hours after executionTimestamp
|
Life-cycle
|
91-507 CP 32 |
For all Counterparty1Designator values - 48 hours after eventTimestamp |
Action Types not applicable for RT Public Dissemination:
- Corrections
- Port In/Out
The above rules are based on a combination of the 91-507 CP and the Proposed Amendments