Generally, investment firms are not required to make any arrangements for their European Market Infrastructure Regulation (“EMIR”) reporting.

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.

Delegated Reporting flow-chart: pre and post-Brexit

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.

Quinn Perrott

Quinn is co-CEO and founder of TRAction and focuses on assisting clients in Europe, Asia and Australia to meet their regulatory requirements with trade and transaction reporting solutions as well as development of the best execution platform. With a background in IT, Quinn started in the financial markets as IT Manager for City Index. He then co-founded and worked as a General Manager at one of Australia’s largest margin FX and CFD providers. Quinn has provided educational sessions to Australia’s regulatory bodies in relation to operational aspects of derivatives and trading platforms.