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© DTCC

GTR MAS Reporting Code of Practice REIT Manager/Trustee Setup Model

Last Updated: 30 May 2014

© DTCC

Structure

2

Topic Page

I. Background and Functionality ………………………………………… 3 II. Potential Compliance Timelines ………………………………………. 4 III. Submission Scenarios - Reporting Obligation

on REIT Manager ……..………………………………………………….. 5 IV. Submission Guidelines for REIT Manager ...………………………... 6 V. Submission Scenarios - Reporting Obligation on Trustee ...…….. 10 VI. Submission Guidelines for Trustee ………...………………………... 11 VII. Regulator Outputs ……………………………………………………….. 15

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Background and Functionality

3

GTR Functionality

Firms can submit and reconcile their trades directly in DTCC’s trade repository. This would be considered a direct submission by the REIT Manager/Trustee or the REIT/Trust

Firms can also choose to delegate their reporting to their counterparty or a third party, who in turn, will report to DTCC

Regardless of the submission method, the party with the MAS reporting obligation and the party of the reportable trade, would need to be onboarded to DDRS (DTCC Data Repository (Singapore) Pte. Ltd.).

Both REIT Manager/Trustee and the REIT/Trust would need to register for a LEI

Submissions should be made using standard DTCC trade submission templates

This document assumes the MAS reporting obligation falls on the REIT Manager or Trustee

Background

Under MAS regulations all OTC trades must be reported to a trade repository. The reporting obligation for 2014 covers Interest Rate and Credit Derivatives asset classes. DTCC provides a number of simple reporting options for compliance with MAS reporting requirements. DTCC offers a centralized and flexible trade reporting solution for participants looking to meet their reporting obligations under MAS. This document is meant to be a guide for REIT Managers and Trustees, who have the reporting obligation MAS.

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Potential Compliance Timelines

4

Firms should consult with their internal legal and compliance team to ascertain their own reporting obligation and compliance date. The table below is simply a guideline.

# Scenario Booked In Singapore? Traded in

Singapore?

Possible “Specified Person” (Reporting

Obligation under MAS)

Legal Entity/Party of the Trade

Investment Manager

Reporting Requirement (according to MAS Rules)

1 Singapore based REIT Manager with a Singapore based Trust/Trustee

Yes Yes REIT Manager / Trustee Trust REIT Manager 1-Jul-14

2 Singapore based REIT Manager with an Offshore Trust

No Yes REIT Manager / Trustee (Offshore) Trust REIT Manager 1-Jul-15

3 Singapore based REIT managed by a Singapore based REIT manager

Yes Yes REIT Manager / Trustee REIT REIT Manager 1-Jul-14

4 Offshore REIT managed by a Singapore based REIT manager

No Yes REIT Manager / Trustee (Offshore) REIT REIT Manager 1-Jul-15

1

2

3

4

* Each scenario has very specific setup and submission requirements

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Submission Scenarios – Reporting Obligation on REIT Manager

5

Submission can be done directly to the GTR, or can be delegated. Firms would need to communicate with the appropriate parties if they choose to delegate.


Who has the reporting

obligation?

Who is the Legal Party of the trade?

Who will submit the trade? Scenario #

REIT Manager Trust / REIT

Trust / REIT R4

Third Party R3

Counterparty R2

REIT Manager R1

© DTCC

Submission Guideline for REIT Obligation - R1

6

Inbound Submission

Setup and Onboarding Requirements DDRS Invoice

EOM DDRS Invoice would be sent to:

Trust / REIT, if onboarded directly to DDRS

If Trust / REIT is onboarded through the REIT Manager, then REIT Manager

* Either directly or through the REIT Manager (as multi managed)

Data fields of the inbound submission should contain: Data Submitter – LEI of REIT Manager Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of REIT Manager

LEI Required? Onboard to DDRS?

REIT Manager Yes Yes

Trust / REIT Yes Yes*

Data Submitter

Submitted For

Trade Party 1

Trade Party 2

Execution Agent Party 1


Trade Party 1 Reporting Obligation


REIT Manager Trust / REIT Trust / REIT Counterparty REIT Manager MAS

© DTCC


7

Inbound Submission






Data fields of the inbound submission should contain: Data Submitter – LEI of Counterparty Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Counterparty Trade Party 2 – LEI of Trust / REIT Execution Agent Party 1 – LEI of REIT Manager

Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Counterparty Trust / REIT Counterparty Trust / REIT REIT Manager MAS




© DTCC


8

Inbound Submission






Data fields of the inbound submission should contain: Data Submitter – DTCC Account of Third Party Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of REIT Manager

Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Third Party Trust / REIT Trust / REIT Counterparty REIT Manager MAS




© DTCC


9

Inbound Submission



Trust / REIT

Data fields of the inbound submission should contain: Data Submitter – LEI of Trust / REIT Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of REIT Manager

Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Trust / REIT Trust / REIT Trust / REIT Counterparty REIT Manager MAS



Trust / REIT Yes Yes

© DTCC

Submission Scenarios – Reporting Obligation on REIT Manager

10

Submission can be done directly to the GTR, or can be delegated. Firms would need to communicate with the appropriate parties if they choose to delegate.


Who has the reporting

obligation?

Who is the Legal Party of the trade?

Who will submit the trade? Scenario #

Trustee Trust / REIT

Third Party T4

Counterparty T3

Trust / REIT T2

Trustee T1

© DTCC

Submission Guideline for Trustee Obligation – T1

11

Inbound Submission




If Trust / REIT is onboarded through the Trustee, then Trustee


Data fields of the inbound submission should contain: Data Submitter – LEI of Trustee Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of Trustee


Trustee Yes Yes


Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Trustee Trust / REIT Trust / REIT Counterparty Trustee MAS

© DTCC


12

Inbound Submission



Trust / REIT

Data fields of the inbound submission should contain: Data Submitter – LEI of Trust / LEI Submitted For – LEI of Trust / LEI Trade Party 1 – LEI of Trust / LEI Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of Trustee

Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Trust / REIT Trust / REIT Trust / REIT Counterparty Trustee MAS


Trustee Yes Yes

Trust / REIT Yes Yes

© DTCC


13

Inbound Submission






Data fields of the inbound submission should contain: Data Submitter – LEI of Counterparty Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Counterparty Trade Party 2 – LEI of Trust / REIT Execution Agent Party 1 – LEI of Trustee

Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Counterparty Trust / REIT Counterparty Trust / REIT Trustee MAS


Trustee Yes Yes


© DTCC


14

Inbound Submission





Data fields of the inbound submission should contain: Data Submitter – DTCC Account (or LEI) of Third Party Submitted For – LEI of Trust / REIT Trade Party 1 – LEI of Trust / REIT Trade Party 2 – LEI of Counterparty Execution Agent Party 1 – LEI of Trustee

Data Submitter

Submitted For

Trade Party 1

Trade Party 2





Third Party Trust / REIT Trust / REIT Counterparty Trustee MAS



Trustee Yes Yes


© DTCC

Regulator Outputs

15

A LEI should be used to identify the REIT Manager/Trustee in all the above scenarios

If either “Execution Agent Party 1” or “Execution Agent Party 2” are populated, the populated values will be reflected on the Regulator Reports.

– Specifically the following fields must be reported: – Execution Agent Party 1 Prefix, and; – Execution Agent Party 1 Value

or; – Execution Agent Party 2 Prefix, and; – Execution Agent Party 2 Value

The ‘Reporting Obligation’ in the regular report would refer to the reporting obligation of the position, not the party

– Eg: If the Trade Party 1 Reporting Obligation is indicated as ‘MAS’ and the Trade Party 1 is not a MAS reportable entity, then the reporting obligation would be the Execution Agent Party 1

1

2

3

Slide Number 1StructureBackground and FunctionalityPotential Compliance TimelinesSubmission Scenarios – Reporting Obligation on �REIT ManagerSubmission Guideline for REIT Obligation - R1Submission Guideline for REIT Obligation - R2Submission Guideline for REIT Obligation - R3Submission Guideline for REIT Obligation - R4Submission Scenarios – Reporting Obligation on �REIT ManagerSubmission Guideline for Trustee Obligation – T1Submission Guideline for Trustee Obligation – T2Submission Guideline for Trustee Obligation – T3Submission Guideline for Trustee Obligation – T4Regulator Outputs

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