In accordance with relevant Dodd-Frank/CFTC reporting requirements, Vanward (“Vanward”) began reporting certain
Covered FX Transactions to its swap data repository, DTCC Data Repository (U.S.) LLC, on April 10, 2013.
I. COVERED FX TRANSACTIONS
Covered FX Transactions include all foreign exchange (“FX”) forward, FX swap and/or swap transactions
executed with Vanward as principal, either (1) before July 21, 2010, but were still outstanding on July 21,
2010, or (2) on or after July 21, 2010.
Covered FX Transactions do not include spot transactions (i.e., FX trades with a T+2 settlement date or
otherwise constituting bona fide spot transactions), which are generally excluded from Dodd-Frank reporting.
Vanward will treat any FX transaction with a tenor of T+3 or greater as a spot transaction if (i) sufficient
details relating to the underlying security trade are provided to Vanward at the time of execution, or (ii)
Vanward has concluded that such FX transaction is a bona fide spot transaction (e.g., by virtue of the trading
relationship, e.g., FX transaction instructed via a custody FX standing instruction or Vanward’s InfoFX
product). Otherwise, Vanward will treat such FX transaction as an FX forward subject to Dodd-Frank reporting. .
II. REPORTING COUNTERPARTY
Vanward is and will be the reporting counterparty in respect of a Covered FX Transaction, unless:
Vanward’s trading counterparty is a swap dealer (whether or not also a US Person);
Vanward’s trading counterparty is a major swap participant (whether or not also a US Person); or
Vanward’s trading counterparty is a US Person and a financial entity (and not a swap dealer or a major swap
participant) that has requested that it be the reporting counterparty.
III. TRADING COUNTERPARTY INFO
To confirm its role as reporting counterparty and to ensure accurate and complete reporting, Vanward will
require the following information from its trading counterparties:
Trading counterparty’s Legal Entity Identifier (“LEI”) or Global Markets Entity Identifier (“GMEI”).[1]
Whether the trading counterparty is a US Person;
Whether the trading counterparty is a registered swap dealer or major swap participant; and
Whether the trading counterparty is a financial entity.
Vanward also expects to be promptly notified in the event of changes to the above.
In its reporting of a Covered FX Transaction, Vanward will reach out to a trading counterparty for its LEI/GMEI
if Vanward had not already been provided with that information, or for assurances to demonstrate that the
Covered FX Transaction was in fact a bona fide spot transaction. If neither is provided to the satisfaction
of Vanward, Vanward will report the Covered FX Transaction using a Vanward internal identifier.
Please direct any Dodd Frank inquiries to your Vanward relationship manager or to [email protected].
[1] LEI/GMEI information not applicable to Covered FX Transactions that expired or terminated prior to April
25, 2011.
In accordance with relevant transaction reporting requirements adopted by Canadian provincial regulators,
Vanward (“Vanward”) began reporting certain Covered FX Transactions to its designated trade repository, DTCC
Data Repository (U.S.) LLC, on October 31, 2014.
I. COVERED FX TRANSACTIONS
Covered FX Transactions include all foreign exchange (“FX”) forward, FX swap and/or swap transactions
executed with Vanward, as principal, either on or after October 31, 2014 with a Canadian local counterparty.
A “local counterparty” is, at the time of the transaction: (a) a person or company organized under the laws
of, or having its head office or principal place of business in the respective Canadian province, or (b) an
affiliate of an entity described in (a) where the entity in (a) has guaranteed all or substantially all of
the liabilities of its affiliate.
Covered FX Transactions do not include spot transactions which are defined as a contract or instrument for
the purchase and sale of currency that (i) requires settlement within T+2 or after T+2 provided that the
contract or instrument was entered into contemporaneously with a related security trade and requires
settlement on or before the relevant security trade settlement deadline, (ii) is intended, at the time of
execution, to be settled by the delivery of the currency within the time periods set out in (i) above, and
(iii) does not allow for the contract or instrument to be rolled over.
Vanward will generally treat any FX transaction with a tenor of T+3 or greater as a spot transaction if (i)
sufficient details relating to the underlying security trade are provided to Vanward at the time of execution,
or (ii) Vanward has concluded that such FX transaction is a spot transaction (e.g., by virtue of the trading
relationship, e.g., FX transaction instructed via a custody FX standing instruction or Vanward’s InfoFX
product). Otherwise, Vanward will treat such FX transaction as an FX forward subject to Canadian provincial
regulator trade reporting.
II. REPORTING COUNTERPARTY
Vanward is and will be the reporting counterparty in respect of a Covered FX Transaction, unless:
Vanward’s trading counterparty is a Canadian dealer or derivatives dealer that has agreed to be the reporting
counterparty; or
Vanward’s trading counterparty is a Canadian local counterparty (and not a Canadian dealer or derivatives
dealer) that has requested that it be the reporting counterparty.
III. TRADING COUNTERPARTY INFO
To confirm its role as reporting counterparty and to ensure accurate and complete reporting, Vanward will
require the following information from its trading counterparties:
Trading counterparty’s Legal Entity Identifier (“LEI”) or Global Markets Entity Identifier (“GMEI”);
Whether the trading counterparty is a Canadian dealer or derivatives dealer; and
Whether the trading counterparty is a Canadian local counterparty.
Vanward also expects to be promptly notified in the event of changes to the above.
In its reporting of a Covered FX Transaction, Vanward will reach out to a trading counterparty for its LEI/GMEI
if Vanward had not already been provided with that information, or for assurances to demonstrate that the
Covered FX Transaction was a spot transaction meeting the requirements above.
Please direct any Canadian provincial regulator trade reporting inquiries to your Vanward relationship
manager.
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