According to this post on the Rule Financial Web site, the FCA are going to ask that all trades which are live on the 12th February 2014 be backloaded on or before then, despite the previous guidance that there is a 90 day grace period to backload such trades.

Whilst this is quite logical in many respects, especially with respect to such trades that are modified within the first 90 days, it is yet another task to perform in an already crowded to do list to be completed by 12th February.

The ESMA guidance on Exchange Traded Derivatives is also eagerly awaited to see if this affects that list.

In the meantime, it is going to be hard to take any sort of holiday over the next few weeks!