ESMA have issued the latest version of their Questions and Answers document on EMIR, which can be found here. They include details of new “level 2 validations” which are to come into force in October 2015. There are a few new answers:
TR Question 12b – Modifying the maturity date – it is stated in the EMIR Regulatory Technical standards (RTS) that once the maturity field has been reported it should not be changed. Instead, if a trade is terminated early the termination date field should be populated, and the maturity date field left with its original values. However, some trades have a moving maturity date field even if not terminated early. For example a calendar trade). The Q+A confirms that if this is the case, the maturity date should be changed using a modification message.
TR Question 20a – Empty fields – The instruction on how to populate empty fields has been made clearer. In the case where the field is not relevant, e.g the equity fields for a commodity derivative trade, the field should be left blank. In the case where it is relevant but cannot be provided, the field should be populated with “NA”. This would include, for example, where the value that needs to be sent is not in the list of allowable values.
TR Question 20b – Level 2 validations – ESMA have published the required level 2 validations in this spreadsheet. The validations apply more detailed rules about the permissible entries to the fields under EMIR. These follow the “level 1” validations which went into force in December, which focused on blank fields. The validations will go into force by the end of October and will represent a significant piece of work for many. Note that the validations will only apply to new trades. A more detailed analysis of the rules will follow.