Many market participants use “delegated reporting” to meet their obligations under EMIR and REMIT. This involves another party, such as the counterparty, reporting on their behalf. This blog post by Gordon Allot of Broadpeak Partners gives several reasons why such reporting may not be on offer in future, which will require market participants to change their reporting strategies.
This letter has recently been published by the Central Bank of Ireland, reminding market participants that under EMIR, they are responsible for all reporting, even if delegating it to another party. There is also a reminder that market participants should be checking messages that come back from Trade Repositories.
With changes to EMIR coming next year, many will now need to optimise their reporting arrangements.