This blog is restarting today after a few weeks’ absence due to personal circumstances. Over the coming days “catch up” posts will be published, as well as a special announcement tomorrow.

In the meantime, last week ESMA published an updated Questions and Answers document on EMIR which can be found here. This version adds TR Question 54 on page 121 which deals with the case where an Financial Counterparty (FC) must report on behalf of a Non Financial Counterparty under the clearing threshold (NFC-). This rule under REFIT commences on 18th June for those NFC-’s that do not opt to carry on reporting.

The answers address which fields the NFC- must provide to the FC and other matters relating to this new type of delegation. The rest of REFIT for NFC’s started to apply last June, as described here. A delay to these requirements due to COVID has also been requested (see here).