On July 2, 2015, the Ontario Securities Commission (OSC) announced that it intends to initiate a compliance review of the reporting requirements of OSC Rule 91-507 Trade Repositories and Derivatives Data Reporting in fiscal 2015/2016.

According to OSC Staff Notice 91-704 the initial focus of the compliance reviews will be on the most active derivatives dealers and their compliance with the duty to report derivatives data to a trade repository under Part 3 of OSC Rule 91-507.  The compliance review will be focused on determining, among other questions: (i) whether the correct transactions were accurately reported within required timelines; (ii) whether reporting counterparties were correctly determined; (iii) whether life cycle and valuation data was reported and updated in accordance with required timeframes; and (iv) whether a Legal Entity Identifier for each transaction counterparty was appropriately reported.  As part of the compliance reviews, OSC staff intend to review dealers’ books and records, including policies and procedures, and interview senior management and key employees.  OSC staff have advised that they may also attend derivatives dealers’ offices to review internal processes and compare internal trade records with reported derivatives data.

Derivatives trade reporting rules became effective in Ontario (as well as Manitoba and Quebec) on October 31, 2014 with the regulators in these provinces recently announcing relief for end users in connection with certain inter-affiliate trades.