Impacts/ Changes to Operations Resulting from G20 Reform
31st August 2015/ Confidential

Reporting – intraday or T+1
Reconciliation – with trade repository
Collateral – portfolio and material terms recs, margin calls
Clearing – Mandatory clearing via direct or by broker
Maintenance of client information – correctly identifying clients
Commonwealth Bank of Australia Confidential

Items in solid colour indicates confirmed dates:
No or Low impact for this project/IT Medium Business/IT Impact High Impact for Project, & IT
Indicates uncertainty in Regulations and/or dates not finalised:
2014/15 OTC Reform Regulation Project Impact Assessment
Jan 15 Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan 16 Feb
Large Trader Reporting changes – Phased dates from 30/09/2014 to Changes to the trade reporting solution 30/04/2016
Substituted Compliance Expiry of Cross Border Relief on 1/12/15 Possible Part 45 & 46 Entity Implementation
Mandatory Execution (SEF’s) – Ongoing timeline linked to clearing
Footnote 513: Relief expires 30/09/15
Margin on Uncleared – IM margin Phase in from 1/12/15. VM required from 1/12/15
Commodity Position Limits & Aggregation
– Date TBC
SEC Requirements
– Quarterly De Minimus Calculations . Implementation dates TBC
Relief exp for Val Reporting of Cleared Trades (letter – 14-90) 30 Jun 15
Central Clearing Interest Rates Q3/4 2015
Volcker Rule – 21 July 2015
UTI Pair & Share
– 1 Oct 2015 (counterparts to agree to UTI)
Client Delegation Phase 3A Credit &
Rates
ASIC Reporting Exemption Expiry : Entity Identifiers , UTI pairing and sharing,
Collateral, Entity Name, Lifecycle, ETD Reporting, unmasking 30 Sep 15
Phase 3A commence rpting of collateral barriers & valuations for credits & rates 2 Nov 15
ASIC Client Delegation Phase 3A Other Asset classes & 3B All Products
12 Oct 15
ASIC Client Delegation Phase 3A Backloading 19 Oct 15
Rpting
– 24 Feb 15
FX Securities Conversion
Transactions Exp 30 Sep 16
Phase 3A commence collateral, barriers and valuations for FX,
Commods and equities 2 May 16
Mandatory Clearing. Q1 2016 (Date TBC) . Final Regs & Determination June 2015
ASIC Margin on Uncleared : APRA consultation Q2/Q3
ASIC Legal Entity Name Exemption expiry (subject to TR capability) – 1 July 2015
HKMA Consultation period
HKMA to set Mandatory
Reporting dates Cam
Reporting : Expanded products and scope. Earliest
May 2015
Mandatory Clearing Q4 2015 (TBC)
FX Reporting Phase 1
‘Booked in’
1 May
Phase 1d Entities Backloading for
Credit & Rates Transactions 1 Apr 15
FX, Credit and Rates derivatives Reporting
‘Traded In’ & Additional Fields – 1 Nov
USI/UTI Feb 2016
Russia, China, Malaysia &
Sth Africa & Japan are being monitored
Mandatory Clearing & MTF’s for Rates & Credit Q3 /4 2015 (TBC)
Margin on Uncleared
Collateral Rpting (CBA date) Oct 2015
Reporting Dead Trades
2016
New Jurisdictional fields 27 March
14/02/15 Version
Reporting Deadline for
Backloading 30 Apr
Monitoring Other Canadian Provinces

CBA cleared their first OTC trade via LCH in March 2012.
CBA was the first Australian bank to clear an AUD swap via the
ASX on the 10 Sept 2013.
CBA has cleared over 10k OTC trades through different exchanges.
In June 2015 CBA participated in the biggest ever AUD swap compression with the London Clearing House – in terms of notional reductions – a total of $4.3 trillion.
CBA is reporting approximately 70k trades to different trade repositories.
Commonwealth Bank of Australia Confidential

Needed to implement a number of tactical solutions to meet tight deadlines.
There were and still are a number of manual processes in place.
Increased resourcing required to handle new processes and extra workload.
Client maintenance issues, needed to ensure clients were flagged against correct jurisdictions within our product systems.
A number of product system changes required.
Commonwealth Bank of Australia Confidential

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Commonwealth Bank of Australia Confidential