Generally, investment firms are not required to make any arrangements for their European Market Infrastructure Regulation (“EMIR”) reporting as stated in our article “Two Weeks Until Brexit: What Should I be Preparing?”
What makes EMIR reporting more complicated is that some investment firms also provide delegated reporting to their corporate clients. For example, a European Union (“EU”) investment firm submits their side of an EMIR report and may also prepare an EMIR report for their United Kingdom (“UK”) corporate client.
As illustrated in the flow chart below, the EU investment firm can submit both trade reports to the same Trade Repository (“TR”) under the current EMIR reporting rules. Following a no-deal Brexit, the EMIR reports will need to be split so that the report for the EU investment firm will be sent to an EU TR, whereas the report for the UK corporate client (submitted from the perspective of the UK client) will be sent to a UK TR.
How can TRAction help?
For those investment firms that are offering delegated reporting to their clients who are not in the same jurisdiction, TRAction is able to split the trade reports and submit them in accordance with the local regulatory requirements.
If you would like to know how TRAction can help you to prepare for delegated reporting following Brexit, please contact us.