An EMIR Trade Reporting Checklist

 

Under the European Market Infrastructure Regulation (EMIR), existing and new derivatives trades must be reported to a registered trade repository beginning February 12.  There’s no official tally on the number of European firms that must register, but some reports suggest many have yet to comply with the rule.

Daniel Corrigan, CEO of CME Group’s European Trade Repository talks about the list of things market participants can do now to be ready for the change.

 

Which trades must be reported?

Subject to limited exceptions, all exchange-traded derivatives and OTC derivatives traded must be reported to a trade repository. Intragroup transactions must be reported as well.

 

By whom?

All financial counterparties, NFCs and central counterparty clearing houses will have to report their trading data.

 

How quickly?

Trades must be reported to the trade repository by the end of the following working day (End of Day T+1).

 

 

What data has to be reported?

Twenty-six information fields of counterparty data (participant IDs, valuations, etc.) and 59 fields of common data (trade details, clearing, contract type, etc) must be reported for each trade. Reporting of certain collateral information will be delayed by a further 180 days from the reporting commencement date.

 

What records must be kept?

Records of any derivatives trades must be kept by counterparties for at least five years following termination of the contract.

 

Is there any historical or back-reporting?

Trades outstanding on August 16, 2012, and still outstanding on February 12, 2014, will have to be reported within 90 days of the reporting start date. Trades outstanding on August 16, 2012 or which were entered into on or after this date and are not outstanding on February 12, 2014, will have to be reported within three years of the reporting start date.

We suggest that participants engage with the trade repositories to determine which is appropriate for them. Our experience with companies reporting under the Dodd-Frank Act in the U.S. was that many waited until the deadline, thereby minimizing their options and ability to negotiate documentation. The industry still has a long way to go in a short period. We urge counterparties to start sooner rather than later.

 

CME Global Repository Services (CME GRS) has 400+ global clients and has recorded 20 million transactions since launch in January 2013.   Find out more about CME GRS here.

A version of this post originally appeared in The Treasurer.

 

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