On November 15, 2018, the Bank of England published a letter sent by its Financial Market Infrastructure Directive to compliance officers of U.K. firms that may be affected by forthcoming obligations under the EU Central Securities Depositories Regulation to report internalized settlements from July 2019.
The BoE considers that the firms likely to be subject to the CSDR's obligations are those with the regulatory permissions for safeguarding and administration of assets or arranging the same. Within this subset of regulated firms, an institution will be considered a settlement internalizer if it settles transfer orders on behalf of clients on its own account rather than through a Central Securities Depository. Settlement internalizers must submit reports to the BoE.
The letter provides details of the information that must be reported and where that information should be sent. The first internalized settlement reports to the BoE are due by July 12, 2019, covering the period from April 2019 until the end of June 2019.
The BoE requests that all firms that have received the letter complete a Settlement Internalization Survey by December 31, 2018. This request applies equally to firms that consider that they will not fall within the reporting obligation.
The letter is available at: https://www.bankofengland.co.uk/-/media/boe/files/letter/2018/internalised-settlement-reporting-under-csdr.pdf and the survey is available at: https://app.keysurvey.co.uk/f/1273106/2011/.
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