Treamo Business Consulting, the suppliers of the EMIRate reporting service, which now has almost 70 companies with 850 subsidiaries using the service, and many other corporates who report external transactions have found that the matching of transactions, of trades for which both legs have been reported to different trade repositories, has either not taken place at all or has failed without them being informed of the reason why the reconciliation failed.

The reason for this is that, although there have already been isolated reconciliation attempts between trade repositories, mostly the checks have not been carried out and often the results are not being communicated. So millions of trades all across Europe have matured without there ever having been a reconciliation. 

Treamo believes that, at the moment, ESMA have no master plan to solve this or whether they have a view as to who is responsible.

Although the good news is that the reconciliation rules have been defined more generously by ESMA, e.g. only the date component of the date/time stamp needs to be reconciled and tolerance thresholds have also been defined for amounts. However, these rules still have to be implemented by all trade repositories.

Demand for EMIR reporting services

Treamo report that “the demand for their EMIRate has risen again noticeably in the last two weeks, particularly from companies who have discovered in the past few months that delegating the reporting obligation for external transactions to banks, even if this is mostly free of charge with regard to the report itself, simply doesn't work the way they had imagined. It is becoming increasingly obvious that the possibility of having all reporting of all trades in a single, easy-to-use and transparent system clearly has its advantages.”

Other independent EMIR reporting services are also reporting increasing demand from corporates from some who have not reported before and from those who are rationalising their reporting arrangements along the lines Treamo describe.completely new and corporates understand more clearly what 

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CTMfile take: Although the authorities are determined to continue rolling out their regulatory programmes, Treasury Peers reports that they found in their latest survey of corporate treasurers that regulatory compliance is no longer top of the agenda. Compliance is third behind 1. IT systems strategy, and 2. organisation leadership and balance of corporate treasury work. Regulation is now regarded as a nuisance and corporate treasurers are looking for tips and tricks to comply at least cost and least efforts. Nevertheless, comply they must, even if it adds nothing to the effectiveness and efficiency of the corporate treasury department.