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EMIR

FIA position paper on ETD reporting under EMIR

The Futures Industry Association has issued this paper on the topic of reporting Exchange Traded Derivatives (ETD) under EMIR. The paper proposes some changes to simplify position reporting of ETDs.

Unlike other reporting regimes around the world, EMIR requires that ETDs be reported by market participants. Many of those who report prefer to do so on a position basis. Holding a position in a Trade Repository makes it easier to submit valuation and collateral updates around the ETD. However, those who wish to maintain positions in a Trade Repository are currently required to observe a complex multi step process, requiring that the underlying trades comprising the position  be sent in a separate channel as well as the position. The paper recommends that the complexity be reduced and only positions sent.

Many in energy and commodities attract “NFC-” status under EMIR, removing the requirement to submit valuation and collateral updates. As a result many only send ETDs as trades.

About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.

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