ETR Advisory have written some notes and thoughts on the Questions and Answers written by ESMA last week.

There are some particularly scary items for example:

• UTIs will need to be attached to backloaded deals, matched with the counterparty. This sounds horrible
• For unhedged intra group deals, the notional will hit the threshold twice (!).

The report can be downloaded here.

The notes have been written with an Energy and Commodities focus, and drill down into certain questions., the notes also list the answers that are felt will particularly interest those in energy and commodities.