With only 8 days until the Go Live of EMIR Reporting of Trades, all market participants should now be at the final stages of testing and refinement. All the data should be flowing through beautifully from source system to the TR system, seamlessly adding the UTI, enriching data with LEIs and product codes. It should be clear whether you are delegating, using a third party or reporting directly. And of course it should now be known what each field means, especially for commodities.

Unfortunately for those in commodities trading, the picture above is rare. There is a great deal of confusion about what various fields mean, especially for physically delivered trades, or those related to physical delivery.  For example:

• There is no way to represent a trade that spans two commodities such as a spark spread.
• Most TRs have a limit on the number of delivery legs that can be sent which is much lower than reality. This means that there is no way to represent these trades.
• The “Physical forward MTF” rule needs to be applied. It will be necessary to use the execution venue as part of the algorithm for determining whether a trade is in EMIR.

While these and other questions are outstanding, everyone is still expected to report next Wednesday. Good luck!