Questions and Answers on the Reporting Order

22/05/2016

General

Is there a difference in reporting for residents of Israel and nonresidents?

The report format is the same for everyone.

Is there a reporting threshold?
The reporting requirement applies to a portfolio manager, Tel Aviv Stock Exchange member, financial intermediary, nonresident, or foreign bank regarding its branches outside of Israel, any of whom carried out, whether on their own behalf or for others, foreign currency derivative trades in the preceding 12 months, at an average daily amount of at least $15 million.
The reporting requirement applies to banking corporations and foreign banks’ branches in Israel on a transaction of any value, without any threshold.

Is a report to be submitted only for a trade that exceeds $15 million?

The reporting requirement applies on the execution of foreign currency transactions at an average daily amount of at least $15 million in the past year. From that point onward, the reporting requirement applies to all trades that are executed.

Is there a difference between a banking corporation’s branch abroad and a banking corporation’s subsidiary abroad?
A banking corporation in Israel is to report regarding all its branches, including those abroad.
Subsidiaries abroad are to report in nonresident format, as they are separate legal entities.
A foreign bank is to report for all its branches abroad separately from its report for branches in Israel.

Should a file be reported if no trades were executed during a trading day?

Yes. An empty file should be submitted.

Daily / Monthly Reporting

The reporting files are divided into various subjects, what is to be reported under each one?
Daily reporting is to include only Part A, with Part A(1) referring solely to foreign currency derivatives, and Part A(2) referring solely to index and interest rate derivatives.
Monthly reporting is to include Part A and Part B. Part A is to include transactions executed during the month, whether or not they were closed out. Part B is to include the value of transactions that have not yet been exercised or reached their termination date.

In the daily/monthly reporting, should Part A(1) and Part A(2) be reported in one file or in two separate files?

The two parts are to be reported in one file. Similarly, Part A and Part B of the monthly report are to be reported in one file.

In the daily report, do all the transactions executed and reached their termination date during the reported day need to be included?
In the daily report, all the transactions executed—whether they were reached their termination date or not—are to be reported. In addition, transactions that were recorded or set up during that day, are to be reported, even if they were executed on a previous day.

Reporting Fields

What are the key fields?

The key fields are Field 4 (Identifier of reporting counterparty), Field 9 (Execution timestamp), Field 10 (Event type), Field 12 (Unique transaction identifier—UTI), and Field 13 (Record number).

In Field 5 (Contact Person's Email), what needs to be reported?

Report the email address of the reporting company’s contact person, who can be contacted for clarification regarding the report.

In Field 5 (Contact Person's Email), may more than one email address be reported?

No. Only one email address is to be reported. It is recommended to report an email address that is accessible to a group of contact people.

What occurrences are to be reported in Field 10 (Event type)?
1. Any transaction reported for the first time should be marked in this field with the letter N (new).
2.  When a transaction is cancelled, a record should be reported with the key fields of the cancelled transaction, and to mark the letter C (cancelled) in the field.
3. When a transaction is changed/revised, a record should be reported with the new data and the field should be marked with the letter M (modify).

How should a cross currency swap or FX swap transaction be reported, when it has more than one record?
A different number for each record should be reported in “Record number” (Field 13).
In an FX swap transaction, report the 2 records as spot/forward instruments, with a different record number.
In a cross currency swap transaction, report the details of the interest rate and principal exchanges in one record, and a different record for each exchange of principal from New Shekels to foreign currency.

How should the value be reported in a cross currency swap in Part B of the monthly report?

Report the value of the transaction in one record, including the interest rate exchanges.

In Field 14 (Trading Capacity)—what is Agent/Principal?
When the reporter is not a party to the transaction, report as Agent.
When the reported is a party to the transaction, report as Principal.

What is the meaning of “beneficiary” in Field 15 (Beneficiary ID type), Field 16 (Beneficiary ID), and Field 17 (Beneficiary name)?

The beneficiary is the entity on whose behalf the transaction—to which the reporter is not a party to—was made.

How should transactions executed vis-à-vis branch customers be reported in Field 19 (Identifier of counterparty 1), Field 21 (Identifier of counterparty 2 type), and Field 22 (Identifier of counterparty 2 (non-reporting counterparty))?
Branch customers are to be reported in aggregate, by residency, currency, and direction. Every record is to be reported under a different “unique transaction identifier” (Field 12).
In Field 19 (Identifier of counterparty 1)—report the reporter’s ID number.
In Field 21 (Identifier of counterparty 2 type) identifier type)—report O (=other).
In Field 22 (Identifier of counterparty 2 (non-reporting counterparty))—report:
            For a resident of Israel: IL100000001
            For nonresidents: US100000001

How should an IRS transaction which was exercised before maturity date or an option that was exercised before maturity date be reported?
Report the record while marking “Event type” (Field 10) with an M (=Modify).
In addition, the transaction’s end date should be changed to the same day on which it was closed.

How should an IRS transaction that was created as a result of a Swaption be reported?

Report a regular IRS transaction while in the “Event type details” field (Field 11) record the note “option exercise”.

Should a shekel/foreign currency option be reported on the exercise date as well?

When an option is exercised, a Spot transaction is created. This transaction should be reported as a new record and in the “Event type details” field (Field 11) record the note “option exercise”.