Unpaired EMIR Reports – The Need to Share a UTI

With EMIR Refit around the corner, regulators are increasingly turning their attention to the accuracy of transaction reporting by firms in their purview. We have recently seen CySEC making enquiries to investment firms about pairing and matching discrepancies that have been identified in their EMIR reports.

ESMA Data Quality Report – Improving Valuation Reporting

The ESMA 2022 Report on Quality and Use of Transaction Data is a study conducted by the regulatory authority to assess the quality and utilisation of transaction data across the European Union (EU). The report analyses various aspects of transaction data, including missing valuations, which are an important component of accurate and reliable market analysis. One trend highlighted is that the number of reports with missing valuations is declining. This is something that ESMA have been targeting for years, as the valuations give the regulator a much better picture of the overall systematic risk by having a better understanding of the aggregate exposure being held in the OTC marketplace.

EMIR Refit: Unique Product Identifier (UPI)

EMIR Refit will see the introduction of a new field – the Unique Product Identifier (UPI). The UPI is being added to EMIR, as well as other regimes such as ASIC, MAS and CFTC derivative reporting so as to more closely align regulation worldwide.

LEI Requirements

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’

EMIR Data Quality Is Now A Regulator Focus

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.

Do UK NFCs Trading With an Offshore Broker Inherit Their Reporting Responsibility?

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.

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