Delta Capita EU EMIR Refit Timeline 2023-2024

August

Gap Analysis

 Identify what requires adjustment to align to your current technology, personnel & processes.

 Understand the scope of change and build an implementation roadmap.

 Roll up non-urgent items in the refit plan.

Data Sourcing

 If unable to acquire all necessary data, begin formulating strategies for populating the mandatory information.

 Thoroughly review conditional fields in relation to your workflows.

Functional Requirements

 Action type and event type analysis need to happen, instrument level mappings need to be produced, a revised business process for UTI and a new business process for ISIN/UPI/CFI need to be produced

September (Now)

Service Provider Integration

 If you plan to involve a service provider in any phase of your lifecycle, it's important to have already chosen the preferred vendor and finalise contractual agreements.

 Keep in mind that you may require licensing for UPI

September - November

Test Plan

 A detailed plan and timetable for testing tasks should be established. Any teams assigned to testing must receive training on the modifications and the roadmap for implementation.

March - April

Go Live Preparation

TIMELINE & ILLUSTRATIVE ACTIVITIES

December - February

Solution Development

 Arrange defects based on their severity and determine which ones can be deferred until after the go-live phase.

 Organize internal forums to assess whether any of the fixes required after the golive phase necessitate regulatory notification.

2023 - 2024

End-to-end Testing

 Data should flow from vendor/source/internal systems to the TR and back in.

 Prioritise test plan completion.

UAT Preparation

 UAT is open at the primary EU TRs. If your company is of a larger scale, it's advisable to initiate testing during the autumn season.

 Given that the end of the year falls within the testing period, it's essential to conduct a certain amount of testing before the focus shifts to holiday celebrations.

Operating Model

 Processes for controls and oversight need to be developed, delegated reporting agreements need to be signed, revised target operating model to be agreed with all stakeholders

 Business rules, xml transformation and daily trade, valuation and collateral submission technology platform development need to happen in this time

Accuracy Checks

 Testing of high priority flows should be almost complete.

 From this stage onward, the accuracy of your system to TR reports should commence. Despite receiving confirmations at the TR, it's important to note that they might not necessarily mirror your internal system accurately.

 Defects might arise, making it advisable to not to postpone this task until the later phases of the project.

 Establish clear handover instructions and documentation, ensure the production teams are trained and aware of any unresolved matters.

Code Lock Down

 Lock down code at least 2 weeks ahead. Prepare to execute runbooks.

Week Before Go Live

 Reiterate the runbook plan to global teams and service providers, confirming you possess the correct contacts for a seamless transition.

 Have dedicated cross functional staff for the weekend of April 27th

May

Post Go Live

 Day 2 Plan Remediation

 The remaining open trades need to be upgraded to the new format and submitted.