ESMA has released an updated version of the Questions and Answers document on EMIR, which can be found here. There are several updated answers, including:

• OTC 18b – p35 – on the handling of omnibus accounts in indirect clearing arrangements in the case of a default.
• TR 31 – p73 – on the reporting of collateral.
• TR24 – p103 – on the buy/sell flag used for swap reporting.
• TR34 – p110 – on reporting trades such as CFDs with no maturity date.

The new version follows more significant changes published around the time that the new EMIR RTS took effect (see here).

Subscribers to ETR Advisory’s Regulatory Support service will receive full comments on these updates (see here).