Two days have now passed since the Go Live for EMIR Reporting of Trades. The true picture of how it went is emerging, with a surprising lack of disaster stories so far. This account on The OTC Space shows some feedback from the financial sector. In the energy sector, most who were a) ready with trade data and b) had their accounts set up properly, managed to send the majority of their trades. We have received no reports of major outages of any TRs, with only a few minor glitches along the way.
Those who did not succeed in sending any data fall into two main camps:
- Those who did not have their accounts or LEIs set up – there are quite a few of these. On boarding times at TRs and also for obtaining LEIs went up as the deadline approached, due to the increased volume. Some still do not have accounts/LEIs. Some left it late and some did not have the correct account type.
- Those who left it very late – in many cases in energy there was a very late start to EMIR projects, TR selection etc. Some simply did not leave enough time.
At around 6pm on Feb 11th, ESMA issued their latest Questions and Answers document. Not great timing. Attention is now being paid to some of the answers, and in particular those around UTIs. The Q+A outlined a UTI construction scheme that most had not heard of before. It will take a couple of weeks for that to be digested to see how it will be supported.
We now expect reconciliation to start in earnest the no doubt large number of mismatches is going to highlight the very different approaches participants have taken to reporting trades, in particular commodity trades. Hopefully the discussion on what really goes in each field will result in some clarity.
So, we expect a few weeks of tidy up to take place, before setting our minds to REMIT. No definite date yet but certainly something to think about. That and the effects of mandatory clearing, even for NFC-s will be the next topic for us to worry about.
And don’t forget annual portfolio reconciliations on the 15th March.