In only one week, the Go Live for EMIR Reporting of Trades, GLERT, will be upon us. As we saw yesterday, the picture for those in commodity trading is far from clear.
So what should we all be doing in the remaining week?
Maria Leontiou has published a great guide from a banking perspective, and there are many others. However as we have already seen, the majority will not be completely ready.
In commodities, the “spectrum of readiness” is quite wide: Some started some time ago, some started days ago. And yet, the chances are that no matter where you are on the spectrum, there are still outstanding questions, uncertainties and issues. Be they on the data format to use for commodity trade, UTIs, exchange traded derivatives or delegation, things are unlikely to be perfect.
So what should one do if it looks like not everything will be ready? Some thoughts:
- Send what you have – there is lack of convergence on what many of the fields mean, but even so send in what you can (without misrepresenting). The reconciliation that will take place after the deadline will lead to a great deal of breaks, followed by further discussion on what is really required in those fields. Expect that process to take several weeks
- Keep going – in the event of a problem, the more you do, the better the regulator is likely to treat you upon audit. Regulators are likely to be reasonable given the confusion that has taken place around EMIR, as long as you have done your utmost to meet the deadline. Now is not the time to slow down. And if you are not finished on the 12th keep going after the deadline until all is well.
- Don’t panic!