With the separation of EU and UK requirements and the beginning of divergence, determining whether your firm needs to complete RTS 27 and 28 reports can be very confusing. We summarise the current status of each report across both regimes.
Are you reporting trades by New York (NY) time or following NY close of business? If so, it is important to check your trades/transactions are still reported at the correct time now that daylight saving time (DST) has started in the US (13 March 2022).
There are certain fields within EMIR, MiFIR and SFTR which require populating with an LEI or specifically ‘ISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code’
We have recently seen regulators making enquiries to investment firms about pairing and matching discrepancies that have been identified in their reporting.
TRAction is pleased to introduce the updated User-Friendly Guide to Transaction Reporting in Europe. The team at TRAction have refreshed our well-known guide for those reporting under EMIR and MiFIR/MiFID II in both the UK and Europe.
Since the introduction of transaction reporting, firms have spent significant proportions of their compliance budget on the initial implementation and ongoing technological solutions to ensure transactions are being reported to the regulators correctly and on-time.
Article 9(1)(a) UK EMIR requires non-financial counterparties (NFCs) who benefit from mandatory delegated reporting when trading derivatives with a financial counterparty (FC) to report both sides of their trades with NFC- entities, unless the NFC- entity has specifically requested otherwise. This reduces the burden on smaller non-financial counterparties.
Following a series of reviews that the Cyprus Securities and Exchange Commission (CySEC) has recently carried out on EMIR data quality being submitted by Regulated Entities to Trade Repositories (TR), they outlined several areas of concern in Circular C545.
MiFID II and MiFIR commodity derivatives