Information for issuer agents on their reconciliation obligation
Background
The CSDR Level 2 text (Delegated Regulation (EU) 2017/392) Articles 61 and 62 require CBF1 to perform a daily reconciliation with registrars and transfer agents.
For this purpose, CBF will generate on a daily basis a reconciliation report for those CBF customers acting as issuer agents (emissionsbegleitende Institute; EBI). The report will be made available as from 14 May 2018 and contains the total Issue Outstanding Amount (total IOA) of all relevant fund and registered securities (except those already reconciled via CASCADE-RS2).
Reconciliation process
CBF provides reconciliation reports via CBF Fileservice to customers acting as issuer agents. Therefore, concerned issuer agents must maintain an access or must register for an access to CBF Fileservice. All issuer agents will be automatically subscribed to receive the report as soon as the CBF Fileservice connectivity is established (see Sample Reconciliation Report in the Attachments section).
CBF customers acting as issuer agents must reconcile the report daily with the information filed in the ownership register of the registrar and with the records of the transfer agent or the entity acting in this capacity. The reconciliation for fund securities can be performed in accordance with the NAV frequency of the relevant fund. Any identified mismatch or discrepancy must be reported to CBF – Controls Frankfurt Safekeeping via email to CFSUnit@clearstream.com within the business day following the reception of the report from CBF. Customers acting as issuer agents must provide all information necessary to enable CBF to ensure the integrity of the issue.
Connectivity form
In order to be able to receive the reconciliation reports the relevant customers acting as issuer agents must ensure they are able to use the CBF Fileservice. The subscription to receive the reconciliation report will be performed automatically by CBF.
Customers acting as issuer agents currently not using the CBF Fileservice must complete and submit Connectivity Form 22 Registration for CBF Fileservice via ClearstreamXact . The form can be submitted to CBF as a scan via email or by post.
For related connectivity questions customer can contact Client Services Connectivity.
Further information
For further information customers may contact the Clearstream Banking Client Services Connectivity, Controls Frankfurt Safekeeping, the CSDR Customer Readiness Team or their Relationship Officer.
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1. Clearstream Banking refers to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in the Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500 (CBF).
2. There are no changes to the reconciliation process via CASCADE-RS. Issuer Agents are not expected to reconcile registered securities which are already being reconciled via CASCADE-RS.