1. Benelux Forum – March 2014
Richard Young
Regulatory Affairs - SWIFT
richard.young@swift.com
Regulation Update
2. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
3. G20 Commitments & EU Single Market –
Driving Regulatory Change
G20 Commitments
• Capital
Requirements/Capital
Buffers
• Liquidity Monitoring
• Shadow Banking Industry
regulation
• Greater Market
Transparency
• Safer OTC Derivatives
• Robust Market
Infrastructure
EU
• Progress the Single Market in
Financial Services by
continuing deployment of
measures to remove barriers
to cross border transactions.
+
• EU Interpretation of G20
Commitments
3
4. Rule-Making Process
Legislative Process
G20
Policymaking Process
Political Commitment
G20 Commitments & Regulatory Development
ESRB
European Systemic
Risk Board
ESCB
European System of Central
Banks
CGFS
Committee on the Global
Financial System
IASB
International Accounting
Standards Board
IOSCO
International Organisation
of Securities Commissioners
BIS
Bank for
International Settlements
BCBS
Basel Committee on
Banking Supervision
CPSS
Committee on Payment
and Settlement Systems
FSB
Financial Stability Board
ODRF
OTC Derivatives Regulators
Forum
IMF
International Monetary
Fund
ODSG
OTC Derivatives Supervisors
Group
US
Senate
US House of
Representatives
European
Council
European
Parliament
CRD IV
Dodd Frank
Act
MIFID/R
EMIR
CSDR
Congressional
Oversight
EC Endorsement &
EP/Council non-objection
US
Administration
CFTC
SEC
European
Commission
ESMA
EBA
EIOPA
4
Adherence / Compliance
2009
2013+
5. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
6. Changing EU Regulatory Structure – Single
Supervisory Mechanism
• September 2012 - EU propose Single Supervisory Mechanism (SSM) for euro
area.
– A regulation conferring strong powers on the ECB for the supervision of all
banks in the euro area, with a mechanism for non-euro countries to join on a
voluntary basis.
– Focus on decision making in the EBA to ensure balance and integrity of the
single market.
– First step to Banking Union
• March 2013 Deal reached with EU Parliament on the SSM - banks with assets
of €30 billion, or larger than one-fifth of their country's economic output, are
supervised by the ECB rather than national supervisors.
• The next pillar of Banking Union is the SRM (Single Resolution Mechanism).
Ongoing discussions between EU Parliament and Council: member states
decision making powers over bank resolution, which institution would ultimately
be responsible for resolution and the borrowing capacity of the Single
Resolution Fund.
ECB Preparing to take up SSM role from November 2014
7. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
8. SEPA and Payment Services Directive
• SEPA
• Early 2012 agreement reached between EU Parliament, Commission
and Council on SEPA end date. Resulting timings:
− A common and single end date of end January 2014 for the migration of
euro retail credit transfers and euro direct debits to SEPA instruments.
Deadline recently extended to August 2014
− An exclusion of the High Value Payment Systems from its scope.
− Mandatory use of ISO 20022 XML as the standard for euro retail CT and
DD messages for the interbank space AND for customers sending or
receiving bulk files.
− A ban on per transaction Multilateral Interchange Fees (MIFs) for DDs as
from 1 November 2012 for cross-border and 1 November 2017 for
domestic direct debits
− Industry Challenges:
− Corporate Segment Take Up
− Differing Time lines per Geographic Area and Instrument Types –
complexity of Implementation
8
No further deadline extensions beyond August 2014
9. SEPA and Payment Services Directive Contd.
• Payment Services Directive (PSD II) Review
• In July 2013 the EU Commission published legislative proposals to update the
existing Payments Services Directive.
• The new measures consist of a revised PSD Directive, together with a new
Regulation on Multilateral Interchange Fees
• PSD II facilitates and renders more secure the use of low cost internet payment
services by including within its scope new so-called payment initiation services
(PIS).
• Banks, PIS and all other PSPs will need to improve online transaction security
by including strong customer authentication for payments.
• Payment Systems will be required to open up and allow access to ALL PSPs,
subject to appropriate risk assessments including; such areas as governance
and business continuity arrangements, all of which will be overseen by local
regulators.
• The PSD II Regulation on interchange fees imposes a cap on the interchange
fees PSPs can charge for consumer debit and credit card transactions, which
take place within the EU. It will also ban surcharges on such cards imposed
9
When: Agreement unlikely before EU Parliament elections, earliest
implementation 2016?
10. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
11. Basel III and CRD IV
• Capital and Liquidity standards – Implementing Basel III in
the EU.
• Changes to the Capital Requirements Directive (CRD) – new
Regulation and updated Directive:
• Directive covers access to deposit taking facilities, regulation covers
prudential requirements including:
• capital: Increasing the amount of own funds banks need to hold as well as the quality of
those funds..
• liquidity: Improving short-term resilience of the liquidity risk profile of financial institutions
with introduction of a Liquidity Coverage Ratio (LCR) - the exact composition and
calibration of which will be determined after an observation and review period in 2015.
• leverage ratio: In order to limit an excessive build-up of leverage on credit institutions' and
investment firms' balance sheets, a leverage ratio be subject to supervisory review is
proposed. Implications of a leverage ratio will be closely monitored prior to its possible
move to a binding requirement on 1 January 2018.
• counter party credit risk: measures are introduced which are consistent with the
regulatory policy for OTC (over the counter) derivatives, i.e. to encourage central clearing
When: Agreement reached Feb 2013, entry into force expected
from Jan 2014 – implementation phased in to 2019
11
12. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
13. Foreign Account Tax Compliance Act (FATCA)
• US tax authorities are concerned that US
persons escape their US tax obligations
by holding assets through offshore
accounts;
• Non – US Financial Institutions designated
as Foreign Financial Institutions (FFIs);
• FFIs suffer 30% withholding unless they
enter into IRS agreement;
• Participating FFIs must identify US
account holders and may withhold
payments to non-participating FFIs or
recalcitrant accounts.
• IGAs increasingly common = reporting to
local tax authority
GIIN – Global Intermediary Identification
Numbers to be added to SWIFTRef
13
When: 25 April 2014 for the initial FFI list, ready for withholding to start from
1st July 2014. Participating FFIs will be expected to begin FATCA tax client
reporting in respect of 2014 information by March 31, 2015.
US Person
Bank
Account
Platform
Insurance
Product
Fund
Custodian
Trust
Broker
IFA/ Wealth
Manager
Foreign
Financial
Institutions
Proceeds from
Income & Sales
US Assets
14. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
15. AML Review (4th AML Directive – AMLD)
The proposals provide for a more risk-based approach based on an understanding of the
AML and Counter Terrorist Financing risks which impact individual countries. The new
Directive:
• Clarifies and reinforces the rules on customer due diligence and introduces new
provisions to deal with politically exposed persons (i.e. people who may represent a
higher risk of corruption by virtue of the positions they hold).
• Goes beyond the FATF requirements by bringing within its scope all persons dealing in
goods for cash payment of €7,500 or more.
• Ensures a more comprehensive coverage of the gambling sector (in the light of concerns
that the sector is vulnerable to money laundering) and includes an explicit reference to tax
crimes (tax evasion)
• Includes a reinforcement of the sanctioning powers of the regulators by introducing a set
of minimum principle-based rules to strengthen administrative sanctions and a
requirement for them to coordinate actions when dealing with cross-border cases.
15
• This review is to the existing 3rd Anti Money Laundering
Directive which was adopted in 2005 and transposed into
EU Member States' legislation in 2007.
• AMLD implements international standards set by the
Financial Action Task Force (FATF) on anti-money
laundering and terrorist financing. The 4th AMLD will
include standards updates made by the FATF in 2012.
16. • Example; payment service providers must ensure the transfer of funds is
accompanied by information such as:
– the name of the payer;
– the payer's account number, or a unique transaction identifier
– the payer’s address, or national identity number, or customer
identification number, or date and place of birth.
– the name of the payee; and
– the payee's account number or a unique transaction identifier
• The new Recommendations also have strengthened transparency
requirements for reliable information to be available about the ownership
and control of companies, trusts, and other legal persons or legal
arrangements.
AML Review (4th AML Directive – AMLD) – Contd.
Improving Transparency
16
When – Legislation Feb 2013, Council and Parliament discussions during
2014. Implementation 2015?
• Along with the general review of the AMLD there is a
also a Regulation on the information accompanying the
transfer of funds.
17. Financial Sanctions
• Sanctions lists are increasingly imposed by national governments and
bodies such as the EEAS and the UN in pursuit of foreign policy objectives
and to fight crime and terrorism.
• Compliance with Sanctions regimes is a challenge for the financial industry
(and for SWIFT).
18. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
19. EMIR – European Market Infrastructure Regulation
• Moving OTC Derivatives as far as possible to centralised clearing through one or
more CCPs - G20 Commitments
– ESMA will decide the derivatives contracts across asset class included in
mandatory central clearing;
– All EU counterparties must comply – although exemptions for non-financial
counterparties below ‘clearing threshold’, intra-group transactions and pension
schemes.
• Standardisation of OTC Derivatives contracts permitting exchange trading and
clearing;
• Non-cleared derivatives subject to bilateral risk mitigation; G20 Commitments
• Increased market transparency via reporting to Trade Data Repositories (at least
one per asset class). G20 Commitments
When – Entry into force August 2012; Reporting Feb 2014, Clearing
obligations – Q4 2014?
19
20. EMIR – Contd. - Focus on CCPs
• EMIR includes rules for the operation of CCPs including:
– Client asset segregation; CCPs must offer an account structure so that Clearing
member assets can be distinguished from the assets of the CCP and Clearing
member client assets can be distinguished from the Clearing members assets
(omnibus segregation). The CCP may also, at the request of a clearing member,
set up individually segregated accounts in which the positions and assets of
indirect clients of a client may be recorded, but there is no obligation to do so.
– CCPs must collect margin limiting credit exposure from clearing members until
the liquidation of the relevant positions. The margin must be sufficient to cover
losses resulting from 99% of exposure movements over a time horizon. Margin
calls will be collected on an intra-day basis. Margins collected must be adequate
to cover the risk stemming from positions registered in each individual client
segregated account.
– Further measures to limit CCPs credit exposures are contained in the
requirements for pre-funded default funds to cover losses not covered by margin
requirements.
20
21. EMIR - Contd. - Focus on Non-Central Clearing
• EMIR also covers non-centrally cleared OTC derivatives. Some technical
standards are still under development, but will take their starting point from
the BCBS-IOSCO work.
• EMIR mandates risk mitigation for non-centrally cleared trades including:
– Timely confirmation (phasing in, but for financial counterparties this will be
required by T+1 from later in 2014), ideally by electronic means;
– Portfolio reconciliation and dispute resolution;
– Daily mark to market of outstanding contracts;
– Risk-management procedures that require the timely, accurate and
appropriately segregated exchange of collateral (note: it is expected that
the EMIR rules in relation to the margining for non-centrally cleared
derivatives will be largely based on the BCBS-IOSCO framework and will
have a similar application timeline)
– Capital hit to cover risk not protected by collateral exchange
Reminder - Cleared or not-cleared - all transactions need to be reported
– by both counterparties 21
22. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
23. MiFID Review – Markets in Financial Instruments
Directive
• Originally implemented in November 2007 to promote greater competition in securities
trading across the single market, review includes G20 commitments on Derivatives
trading.
• MiFID Review: Revised Directive and new Regulation (Mifid & Mifir)
• The review includes:
– increased transparency and oversight in respect of the trading of derivatives,
including pushing OTC derivatives trading as far as possible onto regulated platforms
– G20 Commitment;
– a new type of regulated trading venue – Organized Trading Facilities (OTFs), OTFs
will provide an additional channel for the trading of bonds, structured finance
products, emissions allowances and derivatives;
– increased transparency across asset class, with expanded pre and post trade and
transaction reporting obligations for all types of traded securities;
– new rules around high frequency trading and place restrictions on commodity
derivatives;
– a harmonised third country equivalence regime, including passporting;
– removal of barriers for access to post-trade infrastructure.
When: Political Agreement in Feb 2014, Level 2 Rule making 2014/15,
Implementation 2H 2016? 23
24. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
25. Central Securities Depository Regulation (CSD-R)
• Regulation of CSDs and Harmonisation of EU Settlement cycle
– Regulatory standards at the EU level for access to and operation of CSDs
– CSD Governance and scope of services
– Cross border issuance of Securities into CSDs (Giovannini Barrier 9)
– Harmonisation of settlement cycles on T+2 (Giovannini Barrier 6) from
2015
plus procedures to address settlement fails
– Full dematerialisation by 2025
– Account segregation
– Trade date confirmation measures
– Support by CSDs for open messaging and reference date standards
When – Political Agreement Feb 2014, Entry Into Force Summer
2014 ESMA Level 2 Q4 2014/Q1 2015
Full Implementation 2015/16
25
26. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
27. Shadow Banking – EU Communication Autumn 2013
• Measures to address Shadow Banking covered in recent EU
Commission communication, included the following areas:
– Increasing transparency, including use of LEI, collection and
exchange of data between authorities and use of trade
repositories, data collection on securities financing e.g. ECB
proposal on repo central repository
– Specific new legislative framework for money market
funds;
– Initiative on securities financing transactions - repo and
securities lending.
– Strengthened Prudential Banking arrangements;
– Greater supervision of the shadow banking sector.
27
28. Shadow Banking Contd.– Securities Financing
Transactions (SFT) – Reporting and Transparency
• An EU framework under which financial and non-financial
counterparties of an SFT will report transaction details to a
Trade Repository (TR). The intention is to build upon the TR
infrastructure which is already in place for the collection of trade
reports relating to derivatives.
• Measures to increase the transparency of the use of SFTs to
investors. The aim here is to ensure that investors are aware of
the risks associated with the use of SFTs. As such UCITS and
AIFMs must inform their investors on the use they make of
SFT’s, as well as of other financing structures.
• Transparency on rehypothecation. Counterparties will retain the
right to rehypothecate assets, but only if the providing
counterparty has granted prior consent
28
When – Political Agreement during 2015, Entry Into Force 2016?
29. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
30. CPSS-IOSCO
Principles for Financial Market Infrastructures (PFMI)
30
Foster
financial
stability
Limit systemic
risk
Increase
safety
Support
greater
efficiency
• Published by CPSS-IOSCO
• 24 principles
• Issued for consultation in 2011
• Finalised in April 2012
• Applied by local supervisors
from 2013
HVPS
LVPS
RPS
SSS CCP CSD TR
Critical
Services
Providers
(annexe F)
CPSS-IOSCO Consultation on the
Assessment of CSPs – December
2013
31. CPSS-IOSCO
Principles for Financial Market Infrastructures (PFMI)
(contd.) – How SWIFT helps Compliance as a CSP
31
PFMI Annex F:
Oversight expectations
applicable to CSPs
Description
SWIFT 3402 and High
Level Expectation
Assurance report
Risk Identification
management
Manage relevant operational and
financial risks
Information Security
Efficient policies to secure
confidentiality & integrity of
information
Reliability and resilience
Be available, reliable and resilient,
including continuity plan
Technology planning
Robust method to plan technology
selection and use
Communication with users
Clear communication to understand
risk management on critical services
√
√
√
√
√
Today, SWIFT supports FMIs in their Compliance…
32. FMI Resolution
• EU Commission expects to publish a legislative proposal for the
resolution of non-bank financial institutions. This will include the
resolution of Financial Market Infrastructures – particularly CCPs and
CSDs.
• EU Parliament has already published an own initiative report on a
recovery and resolution framework for non-banks, which will be voted on
later this year. This has protection of client assets at its core. This
report, along with the FSB consultation is likely to inform the content of
the Commission legislative proposal.
Diagram below, taken from the report, illustrates the default waterfall for a CCP under EMIR
32
33. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
34. Funds Regulation-UCITS
Enhancement to the EU Directive 85/611/EEC from 1985 designed to allow Collective
Investment Schemes to operate freely i.e. be sold ‘across border’ or ‘passported’
within the EU on the basis of authorisation from one member state.
• UCITS V (the latest manifestation of the above) is designed to define the
notion of safekeeping and to clarify custody duties.
• It also proposed to harmonise depositary oversight duties between
different legal structures, restrict delegation to safekeeping duties and
ensure that risks are specified where sub-custodian networks are used.
• It is proposed to clarify depositary liability by introducing a 'strict liability'
standard obliging depositaries to return instruments lost in custody.
• It is proposed to introduce consistent eligibility criteria for depositaries
across the EU, which must be either credit institutions or investment firms
subject to extensive conditions.
When - UCITS V, dealing with depositary obligations (and
remuneration questions) introduced Summer 2012, expected
political agreement 1H 2014, Implementation 2015?
34
35. Alternative Investments Directive (AIFMD)
• The Directive impacts all funds that are not harmonised under the UCITS Directive
e.g. Hedge Funds, Private Equity and Real Estate investment funds
• The Directive:
– establishes a secure and harmonised EU framework for monitoring and
supervising the risks that these funds pose to their investors, counterparties,
other financial market participants and to financial stability; and
– permits, subject to compliance with strict requirements, alternative investment
managers to provide services and market their funds across the internal market
of the EU.
– Defines depositary responsibilities e.g. Depositaries must reconcile their records
with prime brokers’ records and with third parties to whom custody functions are
delegated. Where third parties are used it is still the responsibility of the main
depositary to ensure the safety of the fund’s assets and to ensure that all
obligations for accurate record keeping are discharged.
When – Implemented July 2013 but with transition of 1 year for
existing AIFs, transposition delayed in some states. Further
implementation guidance awaited in others
35
36. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
37. LEI
Local
Operating
Unit (LOU)
Local
Operating
Unit (LOU)
Local
Operating
Unit (LOU)
Central
Operating
Unit (COU)
Board of
Directors
Regulatory
Oversight
Committee
Governance
Operations
•Composed of international financial market
regulators
•Upholds governance principles and oversees
that global LEI system functions for public
interest
•Made up of Plenary & Executive Committee
• Oversees functioning of the COU, operational
integrity and implementation, maintenance of
standards specified by the ROC
• Appointed & overseen by ROC, composed of
stakeholders from financial & nonfinancial firms
• COU ensures the application of uniform global
operational standards and protocols to maintain
uniqueness of LEI and high data quality
• Manages federation through LOUs
• Maintain a central logical database of
identifiers and corresponding reference data
• LOUs provide local provision of all LEI
functions which the Regulatory Oversight
Committee determines do not need to be
centralized.
• Service providers such as local registries and
numbering agencies
37
Defined Infrastructure
SWIFT/DTCC GMEI Utility –
125,000 + Pre-LEIs issued (57% of
the total Pre-LEIs issued – 32% of
which apply to the EU)
38. Agenda
• Section 1
• Background to Regulatory Changes
• The Changing EU Regulatory Structure
• Section 2
• SEPA and Payment Services Directive
• Basel III and CRD IV
• FATCA
• AML & Financial Sanctions
• EMIR
• MiFID Review
• CSD Regulation
• Shadow Banking
• CPSS-IOSCO Principles for FMIs
• Funds Regulation – UCITS, AIFMD
• LEI
• Section 3
• Timetables
39. Q2 ‘13 – CPSS_IOSCO Members
begin assessments
39
2013 2014
Timeline Summary – Key Regulatory Initiatives
Q1 ‘13 – 17 Phased
Implementation
FATCA 1 JULY ‘14 Withholding
obligations introduced
CPSS-IOSCO
Principles for FMIs
Adherence
Basel III
(CRD IV in EU)
Adherence
July 2013 Entry into Force
of CRD IV in EU,
Phased implementation in EU (CRD IV) and
globally 2015 - 2019
2015 2016
February 12 – Reporting
OTC/listed Derivatives
Adherence
European Market
Infrastructure
Regulation (EMIR)
March – TS - Entry into
Force
Q4 2014 beginning of
Clearing obligations
March 2014
Final TextMIFID/MIFIR
CSD-R
Shadow Banking
(Sec. Lending & Repo)
UCITS V
Dodd-Frank
Feb 2014
Final Text Adherence
Jan 14 EC legislative
proposal
Adherence
Adherence
Q1 2014
Political Agreement
AdherenceExpected Rule Making
Expected Rule Making
Adherence
Expected Rule
Making
Expected Rule
Making
Adherence
Expected Legislative Timeline