The FCA has published summaries of their studies on progress in EMIR implementation.

In the study on how NFCs are measuring their Gross Notional Values to assess whether they are over the clearing thresholds, they are concluding that NFCs have the basics covered in terms of marking trades for hedging, with some further refinement required. However they note that NFCs are struggling with the Third Country requirements and also need to be aware that the GNV calculation is a group wide one.

No mention is made of the intricacies of calculating the GNV for commodities trades.

In the study on the implementation of risk mitigation measures by FCs, it was found that the timely confirmation requirements are generally met when the confirmation is electronic. Non electronic trade were harder to confirm in time, especially when the trades did not have standard documentation.

The study then briefly mentions portfolio reconciliation and dispute resolution. It states that firms are currently starting out trying to agree both operational procedures and valuation approaches with their counterparties.