Last week, on 17th June, the next stage of the EMIR “REFIT” programme came into effect (see here for the original post). This was the requirement that Financial Counterparties (FC) who enter into transactions with Non Financial Counterparties under the Clearing Threshold (NFC-) report both sides of the trade unless the NFC- opts out (a form of “compulsory delegated reporting”)  ESMA updated the EMIR Q+A recently to provide further guidance on the process (see here). This article on the Securities Lending Times reports on some of the difficulties that are faced by those who move to the delegated reporting model, in particular when the NFC- uses a different Trade Repository to the FC. This note on the Travers Smith web site also provides more details.

The start of REFIT last year moved the calculation of the Clearing Threshold for NFC-s to from daily to annual. The calculation is to have been carried out between the end of May and the 17th June in order to avoid being classed as “NFC+”