Treamo in their recent newsletter wrote, “The reporting obligation for mark-to-market values and collaterals for NFC+s and FCs came into effect in August. Those of our EMIRate clients who were affected by this were able to fulfill their reporting obligations in good time. So far, around 200,000 trades have already been reported to REGIS-TR via EMIRate (www.emir-ate.com). Our clients appreciate EMIRate's user friendliness and reliability as well as the instant overview of all transactions, both internal and external. Several new clients have complained that their banks still haven't sent them any confirmations of reported trades and they have now decided to take care of their reporting themselves.”
They continued, “Otherwise, there are also a few open issues with regard to reporting in general which mainly relate to the EU-wide harmonization of the reporting obligations. Two questions which are no longer unclear are whether forward transactions have to be reported (they do!) and from when a spot trade is no longer a spot trade (> T+2).”
Apparently, “A major construction site at the moment is the so-called reconciliation between various trade repositories. Although the specifications for this have been available for a long time and, in contrast to the other reporting obligations, these are relative harmless in terms of their contents, the coordination between the repositories doesn't seem to work yet.” Treamo conclude that, “It appears that it is still going to take some time before EMIR is fully operational.”
Switzerland – FMIA (German: FinfraG)
Treamo report that:
- Following the expiry of the consultation-based legislative process and a few adaptations, the Swiss Federal Council has adopted the dispatch on the Financial Market Infrastructure Act (FMIA) on September 3, 2014.
- FMIA is very heavily based on EMIR so that corporates (also the Swiss subsidiaries of EU corporates) at least don't have to expect any new challenges. However, the final executive orders are still pending, meaning that it is still too early to make a final judgment.
- to be kept updated regarding the development of FMIA, check out www.emir-ate.com or sign up their newsletter.
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