Clarifications concerning the syndicated contract identifier

Question

It seems that the criteria for what constitutes a syndicated loan are different across Part II and Part III of the Manual. Furthermore, Example 26 in Section 7.2.1 in Part III suggests that the syndicated contract identifier should be the contract identifier as used by the lead arranger while, in this case, the criteria included in the section stipulate that the syndicated contract identifier should be the combination of “BIC” and “inception date”. Could you please clarify the discrepancies? Could you please also explain why in Example 28 in Part III the entire syndicated loan is reported to AnaCredit, although not all participants are reporting agents that are obliged to report?

Answer

As clarified in Part III of the Manual, in the case of syndicated loans, the value to be reported is the identifier of the contract of the syndicated loan as agreed by all members of the syndicate, irrespective of whether or not the lead arranger reports to AnaCredit. However, the syndicated contract identifier could be reported differently depending on whether or not the lead arranger is a reporting agent under the AnaCredit Regulation. For example:

  1. if the lead arranger is a reporting agent in AnaCredit, the syndicated contract identifier is the identifier applied by the lead arranger to uniquely identify the contract for the purpose of reporting to AnaCredit;
  2. otherwise, the syndicated contract identifier to be reported by all reporting agents participating in a syndicated loan is a combination of the BIC of the lead arranger and the inception date of the syndicated loan (please note that the BIC, also known as the SWIFT-BIC, the SWIFT ID or the SWIFT code, is defined in accordance with ISO 9362).

Importantly, irrespective of whether scheme (a) or (b) above is followed, all observed agents which are members of the same syndicated loan use just one scheme and report the same syndicated contract identifier. In this way, the various instruments that finance the syndicated loan and that are reported by each reporting agent (or by the same observed agent when it acts as the servicer and the other creditors are not observed agents) can be brought together in order to understand the structure of the transaction.

Furthermore, as regards Example 26 in Part III, indeed, it has been adjusted so as to be in accordance with the criteria on the reporting of the “syndicated contract identifier”, where both reporting agents report the syndicated contract identifier as the combination of the lead arranger’s BIC and the inception date (BICBANKLA-15/2/2019). In particular, Tables 74 and 76 have been revised as follows:

Revised Table Indication of the instrument dataset by BANK#1

Date

Reporting agent identifier

Observed agent identifier

Contract
identifier

Instrument identifier

Type of instrument

Syndicated contract identifier

Inception date

31/03/2019

BANK#1

Bank#1

Cnt#1

Loan#1

Other loan

BICBANKLA-15/2/2019 CNTR#A

15/02/2019

Revised Table Indication of the instrument dataset by BANK#2

Date

Reporting agent identifier

Observed agent identifier

Contract
identifier

Instrument identifier

Type of instrument

Syndicated contract identifier

Inception date

31/03/2019

Bank#2

Bank#2

CC#4

INST#2

Other loan

BICBANKLA-15/2/2019 CNTR#A

15/02/2019

Finally, concerning Example 28 therein, please note that, although in this case not all participants are obliged to report to AnaCredit, the entire syndicated loan is reported to AnaCredit because the servicer (i.e. OA#29) is an observed agent. In addition, please note that each share of the loan is reported to AnaCredit only once.

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