ESMA today released a new version of the EMIR Questions and Answers document which can be downloaded from here. The focus is on valuations and collateral reporting which is to go live on 12th August 2014 although there are some other new answers as well. Several items will be of interest to those in energy and commodities, especially the one of reporting of notionals which we have put first on our list, followed by the remaining items:

If the notional of a contract changes due to a life-cycle event over its lifetime this must be reported as a modification (TR Q35). Our comment: Note that for commodity trades, notional is usually a calculated value (price times volume). Given the text of the answer, we would only expect to have to report a modification when the volume or quantity changes, NOT price. 

Collateral Reporting:

• Haircuts should be ignored in reports (TR Q3a)
• If collateral is held in several currencies for a specific trade, they should be converted to a chosen base currency (TR Q3aii)
• Non Cash collateral to be reported as equivalent value (TR Q3aiii)
• Report the sum of initial and variation margin. Only posted collateral to be reported (not received) (TR Q3aiv)
• Report all collateral sent to the counterparty whether they have received it or not (since there is sometimes a transmission time (TR Q3avi)
• Various explanations about what to put in the collateralisation field are in TR Q33

Valuation Reporting

• Use the end of day Settlement price for Mark to market (TR Q3baii)
• Use the absolute value of the contract (TR Q3baiii)
• Those who delegate reporting (and calculation) still retain responsibility for accuracy (TR Q3bd)

Contracts with no maturity date that roll until terminated need to be opened, modified and closed whenever there is any activity (TR Q34)