In two weeks’ time,the Go Live for EMIR Reporting of Trades will be upon us. All market participants will need to send trade information to a registered repository. Last week, we highlighted a list of outstanding issues which included:
- Which data is actually required for certain trade types. In particular, (but not limited to) physical commodity trades.
- How delegated reporting really works
- What to do with Exchange Traded Derivatives (only recently and briefly explained by ESMA).
- How reconciliation will work between TRs and what the consequences are.
- Handing of Unique Trade Identifiers.
- Whether the use of LEIs (or their predecessors) for counterparties is mandatory.
Most of these remain unanswered.
In particular, we await some more guidance on how Exchange Traded Derivatives(ETD) will really work. Whilst there has been the EACH paper, ESMA Q+A, and documents from TRs, CCPs and others, the actual approach is still unclear.
In all likelihood, most will get this wrong, which is exactly what ESMA said would happen when the European Parliament refused to push ETD reporting out to 2015.