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’
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.
Public holidays and bank holidays can have a major impact on trade and transaction reporting requirements; especially if you are an entity operating under multiple regimes.
When there is a public holiday where the regulatory body (or regulated entity) is located, it is likely that the timing of report submissions will be extended commensurately.
Daylight saving time (DST) is coming to an end for most European countries on 31 October 2021. You will need to ensure the time settings in your trade/transaction reporting are correct.
There has been an addition to the Q&As where trading venues are allowed to set instrument-level trading hours for specific financial instruments as long as the trading hours are announced to the public and market participants.
The latest Q&A update is tied to the release of Commission Delegated Regulation (EU) 2022/1302 (RTS 21a) in April 2022 regarding position limits on commodity derivatives and changes to the ancillary activity exemption.
Although these observations are released by the FCA in respect of firms they regulate in the UK, they have significance for all firms subject to the equivalent MIFID II and MiFIR regimes in the EU.