Strategic Consulting | Project Management | Business Analysis

Profound Consulting

Our team has a wealth of knowledge with an average of over ten years of experience in financial technologies. With a broad variety of career backgrounds, coming from swaps and derivatives trading, repo and securities lending, IT services, software engineering and management consulting, Comyno delivers solutions that add real value whether through improved flow, reduced costs or better compliance.

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Strategic Consulting

A decade of experience in financial markets technologies and the regulatory environment is our foundation for the Strategic Consulting services. We work with banks, public institutions, and exchanges to develop business strategies that not only match the regulatory requirements but build and maintain a competitive edge in an industry that is undergoing a structural overhaul.

Best positioned

Project Management

Our academically high ranked and experienced business and IT experts can assist and manage projects of any size for you and assume direct responsibility in-house right from day one. Our Project Management covers assessment of business models, specifications, costs, milestones and deadlines in close collaboration with clients and internal staff.

Smartly coded

Software Development

Comyno has the expertise and power to go even further, in turning the specifications into high quality software tightly integrated into the existing IT environment while the technologies used are given by your standards and the available tools. Our deep technical understanding of many third party software packages, like i.e. trading and risk systems, enables us not only to build the interfaces into your infrastructure, but also to fill the functional gaps. We promise quick time to market, State of the Art user experience and high software quality in order to create the competitive advantage for your business.

Built to last

Analysis & Implementation

Comyno bridges the gap between business requirements and functional implementation with industry leading trends and in-depth knowledge of the whole fintech and regtech universe. Our business analysts and software specialists ensure that your technological and regulatory needs are neatly transformed into your business infrastructure, covering the whole process chain, from initial design up to continuous maintenance.

Securities Finance

The securities finance landscape is about to undergo another drastic change in the next couple of years. Regulations such as Basel III/CRD IV/Dodd Frank Act/ESMA guidelines/EMIR/SFTR, shaped in the aftermath of the 2008 financial crisis, will lead to a change in behaviour of market participants and most likely to a change of the roles and responsibilities of securities finance in banks as a whole. Efficient inventory management, efficient liquidity management and risk mitigation are only some of the new challenges securities finance operations will face in future.

Working with buy-side and sell-side clients alike, we get a global view on what matters most to a variety of market participants. This allows us to directly align our service offering to the needs of our clients, enabling us to define clear project goals and help realising the benefits of the new regulatory landscape and profiting from change. Our expertise covers the full product lifecycle and process chain, from trading platforms, tri-party business, front- and middle-office software to back office operations and subsequent risk- and finance and regulatory reporting requirements.

What we offer our clients:

Target Operating Model definition and implementation
Business case definition and validation
Maintain compliance within the new regulations (Basel III/CRD IV/Dodd Frank Act/ESMA guidelines/EMIR/SFTR)
Connectivity to electronic trading platforms, triparty collateral agents, central counterparties and other third parties
German KAG asset utilisation via Clearstream KAG+ and/or client specific automated in-house allocation algorithms
Project management and coordination
In-house software development

Additionally, Comyno can offers its securities finance software solution C-ONE which offers an end-to-end, front-to-back office solution that facilitates the interaction to various third party service providers such as electronic trading platforms, triparty collateral agents and CCPs in one single platform.

Securities Financing Transactions Regulation

The SFTR (Securities Financing Transactions Regulation No 2015/2365 of the European Parliament of 25 November 2015) is a part of the EU’s efforts to improve the transparency of markets in securities financing transactions. The Regulation introduces the obligation to report details of SFTs to authorised trade repositories concluded by all market participants, including both financial and non-financial counterparties.

Examples of SFTs as understood by SFTR:

securities lending and borrowing,
repo and reverse repo transactions in securities and guaranteed rights,
buy-sell-back and sell-buy-back transactions in securities, commodities and guaranteed rights,
collateral management transactions.

Comyno is already working on different SFTR implementation projects and therefore could also help your firm to comply with this reporting regime in time and within budget. No matter if you are an investment firm, credit institution, insurer/reinsurer, UCITS, AIF, pension fund or CCP and CSD.

SFTR Timeline

12 April 2020 Reporting requirements for credit institutions and investment firms enter into force RTS enter into force. 13 July 2020 Reporting obligations for CCPs and CSDs enter into force. 12 October 2020 Reporting obligations for UCITS and AIFMs enter into force. 11 January 2021 Reporting obligations for non- financial counterparties enter into force. 22 March 2019 Final SFTR, RTS and ITSpublished in the Official Journal of the European Union. 11 April 2019 The transparencyof securities financingtransactions (SFTs) enterinto force. 2019 2021 2020
AIFMs Alternative Investment Funds Managers
CCP Central Counterparty
CSD Central Securities Depository
IST Implementing Technical Standards
RTS Regulatory Technical Standards
UCITS Undertakings for Collective Investment in Transferable Securities

Trade Repository Migration & Reporting Review

Use our converter to switch the trade repository

UnaVista offered with their RulesEngine a service, that took away some burden from the participants, i.e. to create the XML schema for a direct upload into the actual trade repository. With this service now not being available anymore, you will have to create the XML schema yourself as other trade repositories do not provide you with this added value service. We previously already built a converter specific for Unavista RulesEngine specifications into the ESMA XML schema, so you won’t need to reengineer your data in order to send it to Regis-TR or DTCC. If you want to change the trade repository, we can onboard you immediately.

SFTR Solution – Professional Experience & Comprehensive Service

Our SFTR solution is already running in production successfully. We upgrade our SFTR module whenever a new Regis-TR Release is available. We deliver a full service and care about the implementation of new ESMA validation rules and XML schemas (available since 29 July 2021). With help of our professional experience and comprehensive service, you don’t have to worry about upcoming SFTR challenges.

Analysis of your running SFTR solution

Even if you don’t have to switch the trade repository you might have difficulties reporting accordingly and match your data. Comyno is analysing your current reports and approach to help you find the weaknesses/errors of your current SFTR solution.

Please contact Philipp Rothermich (Email:; Mobile: +49 159 01 86 86 01) for further assistance.

Collateral Management/Optimization

Collateral Management has grown in importance in recent years. Once viewed as a support function, it has been forced into the limelight by the 2008 financial crisis. One of the challenges of collateral management is obtaining a consolidated view of positions across the bank. This can be a major challenge in a legacy systems environment where data exists in silos. Also, many market participants have established setups consisting of fragmented systems and manual processes for collateral management in order to ensure compliance with the various regulatory requirements. This makes collateral management a manually intensive, time-consuming and expensive activity for many banks.

Comyno has a deep understanding of the challenges of Collateral Optimisation. We help our clients to create and deliver efficient collateral management processes and optimal collateral allocation strategies quickly and effectively by reviewing relevant business and IT processes throughout your bank, Comyno will also analyse the current operating models, architecture and legacy collateral management solutions and propose strategical and tactical changes.

What we offer our clients:

Design and establish an optimum operating model for collateral management processes
Achieve a centralised view of all eligible assets across the bank
Use individual benchmarks to determine a client specific optimal collateral allocation
Manage and test system and process implementations

Centrally Cleared Securities Lending

Regulations within the OTC derivatives market, namely Dodd-Frank, EMIR etc., have changed the entire market landscape. Soon it will be mandatory to clear certain types of OTC derivative transactions through a central counterparty.

For the Securities Lending market an obligation to clear certain types of transactions through a central counterparty are still a long way off. However, global trends and regulatory directives are moving in favour of CCPs. Part of the Basel III approach is to make using a qualified CCP economically more attractive than conducting a similar transaction on a bilateral basis. Beneficial regulatory capital requirements, a simplified counterparty structure, clear risk management and liquidation/default rules and the elimination of bilateral credit lines are only some of the advantages offered by CCPs to the market participants.

Comyno has a wealth of practical knowledge around the Lending CCP. Not only have we worked on establishing the Lending CCP at Eurex Clearing but also supported the on-boarding process of many participants. Comyno is in the unique position to offer you the best possible services based on our extensive practical experience.

What we offer our clients:

Help validate a business case by performing a cost/benefit analysis
Analyse the impact of the Lending CCP processing principles on our clients existing operating model, determine processing gaps and propose solutions
Develop and implement client specific target Lending CCP connectivity model and STP target operating model
Project management & coordination

Additionally, with the innovative C-ONE Products, our clients can leverage on Comyno’s expertise by using a cost-effective software solution to connect to the Lending CCP services.