The trajectory of digitalisation in the trust, fund and corporate services industry started quite a few years ago and gathered pace throughout 2019 into 2020.
The coronavirus pandemic – which started hitting Europe at the start of 2020 – just accelerated the trend. In April 2020, Microsoft CEO observed that “We [Microsoft] have seen two years’ worth of digital transformation in two months.”
At TrustQuay, we also observed a significant increase in enquiries about digitalisation of services. We have long been aware of the Jersey Registry 2020 Work Programme, which includes implementation of API services (direct submission of data through customer’s software) for a number of regulatory submissions. In the summer of 2020, we engaged with Jersey Financial Services Commission who are leading the way with implementation of the Digital Registry. We have since been closely following the developments and participating in workshops, discussions and providing constructive feedback on implementation proposals.
Jersey FSC are planning for the first phase of Jersey API services to go live with 1 December 2020, with the second phase following in 1 April 2021. At TrustQuay we have already started work to support our customers and enable direct data and report submissions to Jersey Registry through our NavOne and 5Series platforms.
Currently the technical details and the testing protocol are still being finalised by the Jersey FSC. While at TrustQuay we have already started developing the solution, the crucial element will be making sure that the communication between TrustQuay software and Jersey Registry systems works as expected, and that we have built in a sufficient level of business controls to ensure that the data submitted to the Registry is complete and accurate.
In the context of the ambitious Jersey FSC implementation timelines, and technical details still being finalised, all software vendors will face the challenge of balancing the quality of their services with making the API service available as soon as possible. There are multiple dependencies in this process, but the most pleasing aspect is that all the stakeholders share a common vision of accelerating the digitalisation of regulatory filings.
As with any digitalisation project, for the regulated firms, vendors and the Jersey FSC themselves, the preparation will be crucial. Considering that the Financial Services (Disclosures and Provision of Information) (Jersey) Law introduces the concept of ‘significant person’ and a few changes in the beneficial ownership arena, it is most likely that a reconciliation between the current Registry data and source systems will be needed and data updated before the data submissions can be done.
Following the queries from the regulated firms and software vendors alike, the Jersey FSC have reassured the industry that they will make a separate web portal available after 1 December 2020 for any updates and submissions, in parallel with the API services. While we are workings towards enabling direct submission in 5Series and NavOne as soon after the go-live date as possible, it is also reassuring to see such pragmatic thinking so that regulated firms will be able to make their updates and submissions on time.
While for the next few months we at TrustQuay will certainly be busy with implementing the Jersey Registry API services, we are also looking to enable similar digital services in other key jurisdictions, with the intention to speed up digitalisation across the industry and help our customers increase efficiency of their business processes, as well as improve the completeness and accuracy of regulatory submissions.