Recently, Chatham Financial polled more than 200 corporates, real estate investors, and other companies that face or may face EMIR reporting obligations. They, like in the Reval survey, found a large degree of uncertainty surrounding EMIR reporting:

• 59 percent of companies are still preparing for compliance with EMIR reporting
• just 4 percent of companies have completed steps toward compliance
• 35 percent have not yet decided which reporting option to use
• only 18 percent plan to report trades themselves
• 52 percent of respondents are unsure if they are obligated to report under EMIR.

This lack of understanding is reflected in the discussions on LinkedIn, e.g. “I am still struggling to find an answer to one last question...in truth, its not the final question, there is still much more to find out, but for the moment this is a pressing matter.” (The question was about any change to existing will need to be reported afresh. The answer was, Yes.). 

While in other debates on LinkedIn, senior players have been questioning the need for this reporting and how the authorities will know about the trades. Indeed, one commented, “Tens of thousands of companies have no idea these bonkers rule are being implemented.” which is shown by the survey results above.

Others may not be ready either

Not only this, EuroTreasurer magazine reported, not surprisingly, given the short time frames for trade repositories and corporates, that:

• some of the trade repositories testing environments were ‘a little shaky’ but all are now saying they are ‘ready’
• the volumes of reporting (1 million users will have to report their holdings to their trade repositories) are unprecedented
• some corporates were still waiting for their EMIR patches to their treasury management system, let alone having tested their EMIR reporting systems and procedures.

As EuroTreasurer concluded, “a  lot needs to change by Wednesday (12th).”

CTMfile take: The two vital questions for many corporate treasurers are, 1) ”Does it really matter if you are not ready and what are the penalties if any?, 2) “What do you do if you are not going to be ready?”