Singapore: Are Reporting entities who are acting as agents required to report collateral?

Reporting entities who are acting as agents to a reportable derivatives contract, and are not themselves counterparties to the derivatives contract, may not have access to collateral and margin information.  Are such reporting entities still required to report collateral and margin information?

Reporting entities who are executing a reportable derivatives contract as an agent of a  party to the derivatives contract are exempted from reporting collateral and margin  information, if they are not a party to the derivatives contract and it is not reasonably expected of them to have access to such collateral and margin information in their role  as a facilitator to the derivatives contract.  

This exemption does not apply to a fund/REIT manager executing a reportable derivatives  contract for a portfolio that it manages, as the manager are expected to have access to  the collateral and margin information of its portfolio in their role as the manager. 

However, in circumstances where a fund/REIT manager is executing a reportable  derivatives contract as an agent for a portfolio that it does not manage (e.g. where the  trade is routed to the fund/REIT manager as part of its group’s operational arrangements),  the fund/REIT manager can be viewed to be acting only as an agent facilitating the  contract and may rely on the exemption from reporting the collateral and margin  information of the reportable derivatives contracts.